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Agenda 06/25/2024 Item #16K 2 (To execute a Settlement Agreement in the lawsuit styled Willguez Milfort v. Collier County, (Case No. 23-CA-984)06/25/2024 EXECUTIVE SUMMARY Recommendation to approve and authorize the Chair to execute a Settlement Agreement in the lawsuit styled Willguez Milfort v. Collier County, (Case No. 23-CA-984), now pending in the Circuit Court of the Twentieth Judicial Circuit in and for Collier County, Florida, for the sum of $36,000.00. OBJECTIVE: Recommendation to approve the settlement in the lawsuit filed by Willguez Milfort for the sum of $36,000.00 and authorize the Chair to execute the Settlement Agreement. CONSIDERATIONS: This lawsuit arises out of an accident that occurred on October 20, 2022, at or near the intersection of Golden Gate Pkwy. and Santa Barbara Blvd., Naples, Florida. The Plaintiff was rear-ended in a motor vehicle collision caused by a County employee authorized to drive a County vehicle. Accordingly, the County does not have a liability or comparative fault defense available to it and the only issue before a jury will be damages. The Plaintiff produced documentation of a total of $31,396.00 in medical expenses related to the accident which included an emergency room visit, CT imaging of his cervical and thoracic spine, physical therapy/chiropractic care, as well as surgical consultations. The Plaintiff’s pre-suit settlement demand was the statutory maximum amount of $200,000.00 premised on, among other things, a lower back injury requiring ongoing medical care. The parties commenced discovery and depositions were taken. A Court Ordered hybrid mediation/non-binding arbitration was held on June 4, 2024, which produced a settlement of $36,000.00, contingent upon Board approval. The County Attorney and the Risk Management Director recommend that the Board approve this settlement as reasonable. Should the case proceed with additional expert depositions and trial, the litigation costs and the Plaintiff’s potential future medical expenses would exceed the tentative settlement amount. FISCAL IMPACT: Funds are budgeted and available in Fund 5016, Property & Casualty Insurance Fund and the total impact will be $36,000.00. GROWTH MANAGEMENT IMPACT: None. LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority vote for approval. - RTT RECOMMENDATION: For the Board of County Commissioners to approve and authorize the Chairman to execute the Settlement Agreement for the total sum of $36,000.00 in the lawsuit styled Willguez Milfort v. Collier County, (Case No. 23-CA-984), now pending in the Circuit Court of the Twentieth Judicial Circuit in and for Collier County, Florida. PREPARED BY: Ronald T. Tomasko, Assistant County Attorney Michael Quigley, Division Director-Risk Management ATTACHMENT(S) 1. Settlement Agreement- Milfort 062524 (PDF) 16.K.2 Packet Pg. 1806 06/25/2024 COLLIER COUNTY Board of County Commissioners Item Number: 16.K.2 Doc ID: 29079 Item Summary: Recommendation to approve and authorize the Chair to execute a Settlement Agreement in the lawsuit styled Willguez Milfort v. Collier County, (Case No. 23-CA-984), now pending in the Circuit Court of the Twentieth Judicial Circuit in and for Collier County, Florida, for the sum of $36,000.00. Meeting Date: 06/25/2024 Prepared by: Title: Legal Assistant – County Attorney's Office Name: Rosa Villarreal 06/05/2024 2:51 PM Submitted by: Title: County Attorney – County Attorney's Office Name: Jeffrey A. Klatzkow 06/05/2024 2:51 PM Approved By: Review: Risk Management Michael Quigley Other Reviewer Completed 06/05/2024 2:53 PM County Attorney's Office Ronald Tomasko Level 2 Attorney of Record Review Completed 06/05/2024 2:56 PM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 06/05/2024 2:58 PM Office of Management and Budget Blanca Aquino Luque Level 3 OMB Gatekeeper Review Completed 06/07/2024 1:41 PM Office of Management and Budget Blanca Aquino Luque OMB Reviewer Completed 06/07/2024 3:59 PM County Manager's Office Ed Finn Level 4 County Manager Review Completed 06/16/2024 7:43 PM Board of County Commissioners Geoffrey Willig Meeting Pending 06/25/2024 9:00 AM 16.K.2 Packet Pg. 1807 16.K.2.a Packet Pg. 1808 Attachment: Settlement Agreement- Milfort 062524 (29079 : Approval of settlement in Willguez Milfort v. Collier County 23-CA-984) 16.K.2.a Packet Pg. 1809 Attachment: Settlement Agreement- Milfort 062524 (29079 : Approval of settlement in Willguez Milfort v. Collier County 23-CA-984) 16.K.2.a Packet Pg. 1810 Attachment: Settlement Agreement- Milfort 062524 (29079 : Approval of settlement in Willguez Milfort v. Collier County 23-CA-984) 16.K.2.a Packet Pg. 1811 Attachment: Settlement Agreement- Milfort 062524 (29079 : Approval of settlement in Willguez Milfort v. Collier County 23-CA-984)