Agenda 12/12/2023 Item #16K 8 (Authorize County Attorney to file a lawsuit on behalf of BCC against Roberts Drilling, Inc)12/12/2023
EXECUTIVE SUMMARY
Recommendation to authorize the County Attorney to file a lawsuit on behalf of the Collier County Board of
County Commissioners against Roberts Drilling, Inc. and any other responsible parties for $34,073 in
damages caused to a 12-inch water main near the intersection of Mainsail Drive and Collier Boulevard.
_____________________________________________________________________________________
OBJECTIVE: To recover the money spent by Collier County to repair a water main damaged by a negl igent
FDOT subcontractor.
CONSIDERATIONS: On or about January 28, 2020, workers for Roberts Drilling, Inc. damaged a 12-inch
County water main while performing a directional bore as a subcontractor on an FDOT project. The County was
required to engage an emergency contractor and utilize staff resources to restore the County’s 12 -inch water main
and the County incurred $34,073 in damages. Roberts Drilling, Inc. has been contacted by the County’s third-party
adjuster Johns Eastern Company, as well as by the County Attorney’s Office, several times with no responses
received.
The County recommends Board approval to file a lawsuit in county court to recover the damages. Attached is a
draft copy of the complaint, along with corresponding backup materials documenting the damage and amounts
thereof.
By filing this lawsuit to recover damages, the County puts contractors on notice that they will be held responsible
for their negligent actions.
FISCAL IMPACT: The cost to file and serve a Complaint is approximately $450 and funds are budgeted and
available in the Risk Management Property & Casualty Fund (5016).
GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this item.
LEGAL CONSIDERATIONS: This item has been approved as to form and legality and requires a majority vote
for Board approval. -DDP
RECOMMENDATION: To authorize the County Attorney to file a lawsuit on behalf of the Collier County Board
of County Commissioners against Roberts Drilling, Inc. and any other responsible parties for $34,073 in damages
caused to a 12-inch water main near the intersection of Mainsail Drive and Collier Boulevard.
PREPARED BY: Derek D. Perry, Assistant County Attorney
Michael K. Quigley, Risk Management Division Director
ATTACHMENT(S)
1. Draft Complaint - Roberts Drilling (PDF)
2. Backup Documents - Roberts Drilling (PDF)
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12/12/2023
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.8
Doc ID: 27362
Item Summary: Recommendation to authorize the County Attorney to file a lawsuit on behalf of the Collier
County Board of County Commissioners against Roberts Drilling, Inc. and any other responsible parties for
$34,073 in damages caused to a 12-inch water main near the intersection of Mainsail Drive and Collier Boulevard.
Meeting Date: 12/12/2023
Prepared by:
Title: Legal Assistant – County Attorney's Office
Name: Rosa Villarreal
11/29/2023 9:51 AM
Submitted by:
Title: County Attorney – County Attorney's Office
Name: Jeffrey A. Klatzkow
11/29/2023 9:51 AM
Approved By:
Review:
Risk Management Michael Quigley Additional Reviewer Completed 11/29/2023 10:22 AM
County Attorney's Office Ronald Tomasko Additional Reviewer Completed 12/01/2023 1:44 PM
County Attorney's Office Derek D. Perry Level 2 Attorney Review Completed 12/01/2023 2:26 PM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 12/01/2023 2:32 PM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 12/04/2023 10:19 AM
Office of Management and Budget Christopher Johnson Additional Reviewer Completed 12/04/2023 11:34 AM
County Manager's Office Dan Rodriguez Level 4 County Manager Review Completed 12/04/2023 8:49 PM
Board of County Commissioners Geoffrey Willig Meeting Pending 12/12/2023 9:00 AM
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IN THE COUNTY COURT IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL DIVISION
BOARD OF COUNTY COMMISSIONERS
OF COLLIER COUNTY, FLORIDA,
Plaintiff,
vs. Case No.: _____________________
ROBERTS DRILLING, INC., a
Florida Profit Corporation,
Defendant.
_____________________________________/
COMPLAINT
Plaintiff BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY,
FLORIDA (“COUNTY”), by and through its undersigned counsel, sues Defendant ROBERTS
DRILLING, INC., a Florida Profit Corporation (“ROBERTS”) and states as follows:
NATURE OF CLAIMS, THE PARTIES, JURISDICTION. AND VENUE
1. The County’s claims stem from ROBERTS’ damage to the COUNTY’s personal
property, specifically an underground 12-inch water main utility pipe owned, operated, and
maintained by the COUNTY, and the resulting cost of repair incurred by the COUNTY.
2. This Court has jurisdiction over this matter, as it is an action to recover damages in
excess of $8,000 up to $50,000, exclusive of interest, costs, and attorneys’ fees.
3. The COUNTY, as the governing body for Collier County, Florida, a political
subdivision of the State of Florida, and as the ex-officio governing board of the Collier County
Water-Sewer District, an independent special district created by the Florida Legislature, is the
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Packet Pg. 2991 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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owner of the personal property that is the subject of this litigation and is thus authorized to bring
this action.
4. ROBERTS is a profit corporation organized under the laws of Florida, with its
principal place of business at 6261 Buckingham Road, Fort Myers, Florida 33905, in Lee County,
Florida, and is authorized to and does conduct business throughout the State of Florida, including
in Collier County.
5. Venue is proper in Collier County, Florida, pursuant to Florida Statutes section
47.051, because (i) this is an action against a domestic corporation, (ii) Collier County is where
the instant cause of action accrued, (iii) Collier County is where the property in litigation is located,
(iv) the property damage occurred in Collier County, and (v) the amounts due to the COUNTY are
due in Collier County.
FACTUAL ALLEGATIONS
6. In 1993, the Florida Legislature enacted the “Underground Facility Damage
Prevention and Safety Act,” Chapter 556, Florida Statutes (“the Act”), to prevent injury to persons
or property and the interruption of services resulting from damage to an underground facility
caused by excavation or demolition operations. Fla. Stat. § 556.101(3)(a).
7. The Act created a not-for-profit corporation called Sunshine State One-Call of
Florida, Inc. (“the Corporation”), and requires the Corporation to maintain a free-access
notification system (the “One-Call System” or “System”) which excavators can use to notify
owners of underground facilities of planned excavation or demolition activities. See Fla. Stat. §§
556.103, 556.104.
8. The Corporation is comprised of the owners of underground facilities in the State
of Florida, which are called “member operators” by the Act. Fla. Stat. § 556.104.
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Packet Pg. 2992 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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9. The County is a “member operator” under the Act.
10. Under the Act, “excavators” and “excavating contractors” are required to notify the
System and provide information about a planned excavation at least two full business days before
beginning any excavation. Fla. Stat. § 556.105(1). The System then notifies member operators
with underground facilities near the planned excavation, who are required to “identify the
horizontal route by marking to within 24 inches born the outer edge of either side of the
underground facility by the use of stakes, paint, flags, or other suitable means within two full
business days after the time the notification is received” from the System. Fla. Stat. § 556.105(5)
(emphasis added).
11. ROBERTS is an “excavator” and/or “excavating contractor” under the Act.
12. At all relevant times, the Florida Department of Transportation (“FDOT”) was the
owner of a road construction project (“the FDOT Project”) that involved milling and resurfacing,
base work, shoulder treatment, drainage improvements, curb and gutter, sidewalk, guardrail, sheet
pile wall, signing and pavement marking, signalization, and lighting on State Road 951 (Collier
Boulevard) from north of the Judge Jolley Bridge, northerly approximately 3.031 miles, to south
of Fiddlers Creek Parkway, in Collier County (Letting CT190327, Projects 43955515201 and
43955515202).
13. At all relevant times, FDOT was the owner of the FDOT Project that involved,
among other things, road work at or near the intersection of Mainsail Drive and State Road 951
(Collier Boulevard), in Collier County, Florida (the “Intersection”).
14. ROBERTS was to perform excavations at or near the Intersection as part of the
FDOT Project.
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Packet Pg. 2993 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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15. On January 14, 2020, ROBERTS provided a notice of a planned excavation through
the System as required by the Act (the “Notice”).
16. On or about January 14, 2020, in response to the Notice, the County marked with
flags and paint the horizontal route of the County’s underground facilities throughout the
Intersection, including the median of the Intersection (the “Median”).
17. At the Intersection, including its Median, the utilities marked by the County in
response to the Notice included a 12-inch water main utility pipe (the “Water Main”), which was
marked with blue flags and blue spray paint in accordance with the “Uniform Color Code for
Utilities” of the American Public Works Association.
18. On or about January 28, 2020, ROBERTS engaged in a directional drill underneath
State Road 951 as part of the FDOT Project, to install Traffic Signal Conduit, and struck and
caused damage to the Water Main in the Intersection and Median.
19. “If any excavator fails to discharge a duty imposed by [the Act], the excavator, if
found liable, is liable for the total sum of the losses to all parties involved as those costs are
normally computed.” Fla. Stat. § 556.106(2)(b).
20. All conditions precedent to the relief demanded herein have been performed or
waived.
COUNT I –NEGLIGENCE
Breach of the duty to identify and protect underground facilities within the Tolerance Zone of
ROBERTS’ excavation.
21. The County re-alleges and incorporates by reference its allegations in paragraphs
1–20, as if fully set forth herein.
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Packet Pg. 2994 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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22. The Act imposes a duty on excavators to use increased caution to identify and
protect underground facilities when an excavation is to take place within a “tolerance zone.” Fla.
Stat. § 556.105(5)(c). “The protection requires hand digging, pot holing, soft digging, vacuum
excavation methods, or similar procedures to identify underground facilities.” Id.
23. The Act defines “tolerance zone” as “24 inches from the outer edge of either side
of the exterior surface of a marked underground facility.” Fla. Stat. § 556.102(15).
24. ROBERTS’ excavation on or about January 28, 2020, at the Intersection and the
Median, was within the “tolerance zone” of the COUNTY’s Water Main.
25. ROBERTS knew or should have known that its excavation was within the
“tolerance zone” of the COUNTY’s Water Main and the Notice Area, of which the COUNTY’s
Water Main was marked.
26. ROBERTS had a duty to use increased caution to identify and protect the
COUNTY’s Water Main.
27. ROBERTS breached the duty stated in Paragraph 22 by failing to use increased
caution to identify and protect the COUNTY’s Water Main before proceeding with its excavation
in the Intersection and Median on or about January 28, 2020.
28. The damage ROBERTS caused to the COUNTY’s Water Main was the direct,
proximate, and foreseeable result of ROBERTS’ breach of the duty stated in Paragraph 22.
29. As a result of ROBERTS’ negligence, the COUNTY incurred monetary damages
including, but not limited to, the $34,037.00 incurred to repair the damaged Water Main, and other
direct and consequential damages.
30. ROBERTS is liable to the COUNTY for the total sum of the losses incurred by the
COUNTY as a result of ROBERTS’ negligence. § 556.106(2)(b).
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Packet Pg. 2995 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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WHEREFORE, the COUNTY demands judgment against ROBERTS for damages,
together with prejudgment interest and costs, and for such other or further relief as this Court
deems equitable and just under the circumstances.
COUNTY II – NEGLIGENCE
Breach of the duty to perform an excavation in a careful and prudent manner and to exercise due
care in the performance of work.
31. The County re-alleges and incorporates by reference its allegations in paragraphs
1–20, as if fully set forth herein.
32. “Obtaining information as to the location of an underground facility from the
member operator as required by this chapter does not excuse any excavator from performing an
excavation or demolition in a careful and prudent manner, based on accepted engineering and
construction practices, and it does not excuse the excavator from liability for any damage or injury
resulting from any excavation or demolition.” Fla. Stat. § 556.106(2)(c).
33. The Act imposes a duty on excavators to perform excavations in a careful and
prudent manner, based on accepted engineering and construction practices. Fla. Stat. §
556.106(2)(c).
34. ROBERTS had a duty to perform in excavation at the Intersection and Median on
or about January 28, 2020, in a careful and prudent manner, based on accepted engineering and
construction practices.
35. ROBERTS breached the duty stated in Paragraph 33 by failing to perform its
excavation in a careful and prudent manner, based on accepted engineering and construction
practices.
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Packet Pg. 2996 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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36. The damaged caused to the COUNTY’s Water Main was the direct, proximate, and
foreseeable result of ROBERTS’ breach of the duty stated in Paragraph 33.
37. As a result of ROBERTS’ negligence, the COUNTY incurred monetary damages
including, but not limited to, the $34,037.00 incurred to repair the damaged Water Main, and other
direct and consequential damages.
38. ROBERTS’ receipt of information as to the location of the County’s Water Main
does not excuse ROBERTS from the duty to perform its excavation in a careful and prudent
manner, based on accepted engineering and construction practices, and it does not excuse
ROBERTS from liability for the damage caused to the COUNTY’s Water Main. Fla. Stat. §
556.106(2)(c).
39. ROBERTS is liable to the COUNTY for the total sum of the losses incurred by the
COUNTY as a result of ROBERTS’ negligence. § 556.106(2)(b).
WHEREFORE, the COUNTY demands judgment against ROBERTS for damages,
together with prejudgment interest and costs, and for such other or further relief as this Court
deems equitable and just under the circumstances.
COUNTY III – NEGLIGENCE
Breach of the common law duty to exercise due care in the performance of work.
40. The County re-alleges and incorporates by reference its allegations in paragraphs
1–20, as if fully set forth herein.
41. ROBERTS had a duty to exercise due care in the performance of its excavation at
the Intersection on or about January 28, 2020, which required ROBERTS to exercise the degree
of care that a reasonably careful excavator would use under like circumstances.
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Packet Pg. 2997 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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42. ROBERTS breached its duty to exercise due care in the performance of its
excavation at the Intersection and Median on or about January 28, 2020, in the following ways:
a. ROBERTS failed to identify and protect marked underground facilities
within the tolerance zone (i.e., 24-inches) of its excavation.
b. ROBERTS stopped its hand dig at approximately six (6) feet deep when its
excavation at the Intersection and Median had a planned depth of approximately 15 feet.
c. ROBERTS failed to comply with its Drilled Shaft Installation Plan by
failing to hand dig the shaft as required to verify no underground utilities conflict with its
excavation at the Intersection and Median.
d. ROBERTS failed to contact the COUNTY when ROBERTS did not find
the COUNTY’s Water Main during its hand dig.
e. ROBERTS assumed it was clear of marked underground utilities without
identifying and protecting all utilities marked in conflict with its excavation at the
Intersection and Median.
43. The damage caused to the COUNTY’s Water Main was the direct, proximate, and
foreseeable result of ROBERTS’ malfeasance described in Paragraph 45, a.–e.
44. As a result of ROBERTS’ negligence, the COUNTY has incurred monetary
damages including, but not limited to, the $34,037.00 incurred to repair the damaged Water Main,
and other direct and consequential damages.
WHEREFORE, the COUNTY demands judgment against ROBERTS for damages,
together with prejudgment interest and costs, and for such other or further relief as this Court
deems equitable and just under the circumstances.
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Packet Pg. 2998 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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DEMAND FOR JURY TRIAL
The County hereby demands a jury trial on all issues so triable.
Respectfully submitted,
_____________________________
Ronald T. Tomasko
Florida Bar No. 1030999
Derek D. Perry
Florida Bar No. 1018383
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
ronald.tomasko@colliercountyfl.gov
derek.perry@colliercountyfl.gov
nancy.bradley@colliercountyfl.gov
rosa.villarreal@colliercountyfl.gov
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Packet Pg. 2999 Attachment: Draft Complaint - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
FLORIDA • MARYLAND • NORTH CAROLINA • PENNSYLVANIA • VIRGINIA • WASHINGTON, D.C.
NEW JERSEY • DELAWARE
JOHNS EASTERN COMPANY, INC.
P.O. Box 110239, Lakewood Ranch, FL 34211 TEL: (941) 907-3100
October 12th, 2020
Roberts Drilling Inc.
6261 Buckingham Road
Ft. Myers, FL 33905
Our Client : Collier County BOCC
Date of Loss: 01/28/2020
Our File No. : 973211
Dear Roberts Drilling:
As you are aware, Johns Eastern Company is the Third Party Administrator handling
liability claims for Collier County BOCC.
On January 28th, 2020 your company hit and damaged a water main in which is owned
and maintained by Collier County. To date, we have not received payment for costs
related to our damages.
So that we may avoid legal action on this matter, please promptly remit payment or
contact the undersigned adjuster with any questions you may have. When contacting
the adjuster please refer to claim number 973211.
Payment of $34,073.00 should be made payable to: Collier County BOCC. Please
include our file number on the check and mail to the attention of the undersigned
adjuster at:
Johns Eastern Company, Inc.
Attention: Brandon Cooper (claim#973211)
PO Box 110239
Lakewood Ranch, FL 34211
Thank you for your cooperation regarding this matter.
Claim Adjusters &
Third Party Administrators 10/12/2020 9:34:16 AM - Rec'd Johns Eastern Co.16.K.8.b
Packet Pg. 3000 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
ADMINISTRATOR CRITICAL INFORMATION REPORT
Date: January 28, 2020
Specifics of Event: Contractor who we understand at this time was working for FDOT struck the 12”
water main near the intersection with Mainsail Drive on Collier Blvd. Higgins will be completing the
necessary repairs and is in route with MOT and other needed equipment.
R esponse for Corrective Action: Isles of Capri will be out of water during the repair due to the extend
of the damage and the anticipated repair time. A notice is currently being developed/delivered to the
residents of Isles of Capri alerting them to the situation. Traffic is impacted along Collier Blvd. and
CCSO is assisting with traffic directions. Boil water notice is being issued for the Isles of Capri.
Safety/MOT: All safety and MOT regulations are being followed.
What help/assistance do you need:
1. PUD PIO: Copied on ACIR.
2. The Compliance Section/ Lab: (will be called for analysis when/where needed/required): n/a
3. Locates: Locates are being requested by Higgins.
4. Emergency P.O.: Required for Higgins..
5. ROW Permit: Being applied for per SOP.
6. Risk Management: Copied on ACIR.
7. FDEP: Will be notified per SOP.
Manager in Charge:
Name: Pamela Libby
Cell: 253-0215
Radio ID #: D-03
GIS based location m ap:
4/9/2020 9:33:45 AM - Rec'd Johns Eastern Co.10/12/2020 9:34:16 AM - Rec'd Johns Eastern Co.16.K.8.b
Packet Pg. 3001 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
It is the contractors responsibility to verify the outer edge of our marked utility before
excavating within the tolerance zone. This was not done.
556.102(6) 'Excavate" or 'excavation" means any manmade cut, cavity,
trench, or depression in the earth's surface, formed by removal of earth, intended
to change the grade or level of land, or intended to penetrate or disturb the
surface of the earth, including land beneath the waters of the state, as defined in
s. 373.019(20), and the term includes pipe bursting and directional drilling or
boring from one point to another point beneath the surface of the earth, or other
trenchless technologies.
556.102(12) 'Tolerance zone" means 24 inches from the outer edge of
either side of the exterior surface of a marked underground facility.
556.105(5)(c) When excavation is to take place within a tolerance zone,
an excavator shall use increased caution to protect underground facilities. The
protection requires hand digging, pot holing, soft digging, vacuum excavation
methods, or other similar procedures to identify underground facilities. Any use of
mechanized equipment within the tolerance zone must be supervised by the
excavator.
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Packet Pg. 3009 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit
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Packet Pg. 3011 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit
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Packet Pg. 3012 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit
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Packet Pg. 3013 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit
Description of Expense Total
D.N. Higgins Invoice for repair to main and road $26,223
Collier Labor $3,996
Collier Equipment $716
Collier Provided Part - Mega Lugs (2) @ $135 ea.$270
Water Loss - break and flushing of lines after service
restoration 800,000 @ $3.16 per 1,000 gallon $2,528
Laboratory Testing 4 hrs @ 35 ea + 8 Lab Test @ $25 ea.$340
Total Costs $34,073
Collier Blvd at Main Sail Drive Main Break Costs
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Packet Pg. 3014 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file
Collier Labor Breakdown
Tasks
Isolation of main, boil
water notices passed
out, flushing of system
after repair.
Boil water
rescind
notices
passed
out
Road
Repair
Date 28-Jan 29-Jan 1-Feb
Position Last Name Hours Hours Total $ per hour Total
MS Ewart 4 4 $34 $136
MS Vasquez 4 4 8 $34 $272
MS Alvarez 4 4 8 $34 $272
MS Nowicki 4 4 8 $34 $272
MS Wright 3 3 $34 $102
MS Delpozo 8 4 12 $34 $408
MS Haxton 8 4 12 $34 $408
MS Murray 3 3 $34 $102
UT Tye 4 4 $32 $128
UT O'Regan 8 8 $32 $256
UT Caracamo 8 4 12 $32 $384
UT
Temp Team
Member 5 5 $32 $160
UT Rea 4 4 8 $32 $256
UT Vilaspaz 4 4 $32 $128
SR. Crew Leader Gonzalez 12 12 $36 $432
Crew Leader Moreno 4 4 $35 $140
Crew Leader Frields 4 4 $35 $140
Total Labor $3,996
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Packet Pg. 3015 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file
Collier Equipment Breakdown
Position
Last
Name Total $ per hour Total
F150 CC2-1494 4 $13 $52
F150 CC2-1946 8 $13 $104
F150 CC2-565 4 $13 $52
F450 CC2-1556 4 $23 $92
F150 CC2-637 4 $13 $52
F150 CC2-638 4 $13 $52
F150 CC2-1759 4 $13 $52
F150 CC2-637 4 $13 $52
F150 CC2-638 4 $13 $52
F150 CC2-2070 4 $13 $52
F150 CC2-1946 4 $13 $52
F150 CC2-1953 4 $13 $52
Total Labor $716
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Packet Pg. 3016 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file
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Packet Pg. 3017 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3018 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3019 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3020 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3021 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3022 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3023 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3024 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3025 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3026 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3027 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3028 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3029 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3030 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3031 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3032 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3033 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3034 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3035 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3036 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3037 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3038 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3039 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3040 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3041 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3042 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3043 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3044 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3045 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3046 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3047 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
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Packet Pg. 3048 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3049 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)
16.K.8.b
Packet Pg. 3050 Attachment: Backup Documents - Roberts Drilling (27362 : To Authorize the County Attorney to file lawsuit against Roberts Drilling)