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Agenda 08/26/2025 Item #16K 8 (Stipulated Final Judgment for the taking of Parcel 1339FEE for the VBR Ext.)8/26/2025 Item # 16.K.8 ID# 2025-2729 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $93,000 plus $26,959 in statutory attorney and experts’ fees and costs for the taking of Parcel 1339FEE required for the Vanderbilt Beach Road Extension Project No. 60249. OBJECTIVE: To settle full compensation for the taking of Parcel 1339FEE required for the construction of the Vanderbilt Beach Road Extension Project No. 60249. CONSIDERATIONS: On July 9, 2024, the Board authorized, via Resolution No. 2024-135, the condemnation of Parcel 1339FEE for the construction of roadway, drainage and utility improvements required for the expansion and extension of Vanderbilt Beach Road from 16th Street NE to Everglades Blvd. The fee simple acquisition area consists of a strip taking along the rear, southerly boundary of the property and is approximately 0.17 acres in extent. The parent tract is improved with a single-family home and associated improvements and is owned by Peter Cordero and Maribel Cordero. The parent tract contains 1.14 acres of gross land area, which will be reduced to 0.97 acres after the acquisition. An aerial photograph of the subject property is attached. The County’s appraiser estimated full compensation at $38,400 including severance damages. The property owner’s initial demand was $165,600 plus attorney’s fees and expert fees and costs. The parties participated in mediation and reached an agreement subject to approval by the Board of County Commissioners. The attached Stipulated Final Judgement reflects a negotiated compensation amount of $93,000 plus $18,018 in statutory attorney’s fees, $8,941 in expert fees and costs, for a total of $119,959. Staff 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. This item is consistent with the Collier County strategic plan objective to design and maintain an effective transportation system to reduce traffic congestion and improve the mobility of our residents and visitors. FISCAL IMPACT: County is entitled to a credit of $38,400 for its good faith estimate of value. Funds for the balance of $81,559 are available in the Vanderbilt Beach Road Extension Project Capital Fund, Project 60249. The primary funding source for the acquisition of right of way is through Road Impact Fee District Funds (3090, 3091, 3092, 3093, 3094, 3095) in the Vanderbilt Beach Road from 16th to Everglades Project (60249). Should impact fees not be sufficient, the secondary funding source will be Road Construction Gas Tax Fund (3083) and Transportation Capital Fund (3081). GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this action. LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority vote for Board approval. – CMG RECOMMENDATIONS: To approve the attached Joint Motion and Stipulated Final Judgment and authorize the payment of funds as stated herein. PREPARED BY: Robert Bosch, Manager, Manager ROW Acquisition, Operations and Performance Management ATTACHMENTS: 1. Final P1339FEE Joint Motion for Stipulated Final Judgment(1) 2. Aerial - Parcel 1339FEE Page 4469 of 4682 [25-CA-224/1964372/1] 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, Plaintiff, Case No. 25-CA-224 vs. Parcel 1339FEE Allan J. Jones, Trustee of the Allan J. Jones Revocable Trust dated June 17, 2021; Sharon M. Desch; Christopher T. Desch, Jr., Truist Bank, successor in interest to Suntrust Bank; Zenaida Garcia Marti; Jorge Luis Garcia; Jose Luis Garcia; Juana Garcia; Samuel Garcia; Cavalry SPV I, LLC, as Assignee of Citibank, N.A., Customer First, Inc of Naples d/b/a Presstige Printing; Peter A. Cordero; Maribel Cordero; Fifth Third Bank, NA; Fifth Third Mortgage Co; Unknown Tenant(s); Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 1339FEE Petitioner, Collier County, Florida, together with Respondents, Peter A. Cordero and Maribel Cordero, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1339FEE attached hereto as Exhibit “1”. _______________________________ COLLEEN M. GREENE, ESQ. Florida Bar No. 502650 SALLY A. ASHKAR, ESQ. Florida Bar No. 1007665 Collier County Attorney’s Office 3299 E. Tamiami Trail, Suite 800 Naples, FL 34112 Telephone: (239) 252-8400 COUNSEL FOR PETITIONER Colleen.Greene@colliercountyfl.gov Sally.Ashkar@colliercountyfl.gov Sheri.Malcolm@colliercountyfl.gov _/s/ ANTHONY V. POLICASTRO__ ANTHONY V. POLICASTRO, ESQ. Florida Bar No. 937932 Policastro Law Group 1700 N McMullen Booth Rd Ste C5 Clearwater, FL 33759-2129 Office: 727-475-1988 Fax: 727-674-1771 COUNSEL FOR RESPONDENTS PETER and MARIBEL CORDERO tony@policastrolaw.com eric@policastrolaw.com yadi@policastrolaw.com Page 4470 of 4682 [25-CA-224/1964372/1] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the Joint Motion for Stipulated Final Judgment was electronically filed with the Florida Courts E-Filing Portal on this _____ day of ______________ 2025. BY: _______________________________ COLLEEN M. GREENE, ESQ. Page 4471 of 4682 [25-CA-224/1964372/1] 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, Plaintiff, Case No. 25-CA-224 vs. Parcel 1339FEE Allan J. Jones, Trustee of the Allan J. Jones Revocable Trust dated June 17, 2021; Sharon M. Desch; Christopher T. Desch, Jr., Truist Bank, successor in interest to Suntrust Bank; Zenaida Garcia Marti; Jorge Luis Garcia; Jose Luis Garcia; Juana Garcia; Samuel Garcia; Cavalry SPV I, LLC, as Assignee of Citibank, N.A., Customer First, Inc of Naples d/b/a Presstige Printing; Peter A. Cordero; Maribel Cordero; Fifth Third Bank, NA; Fifth Third Mortgage Co; Unknown Tenant(s); Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 1339FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, Collier County, Florida, and Respondents, Peter A. Cordero and Maribel Cordero, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1339FEE for Project 60249, 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, Peter A. Cordero and Maribel Cordero, shall recover from Petitioner, Collier County, Florida, the total sum of Ninety-Three Thousand Dollars and No/100 ($93,000.00) for Parcel 1339FEE, as full payment for the property interest taken, including business damages, if any, in connection with said Parcel. Page 4472 of 4682 [25-CA-224/1964372/1] 2. Respondents, Peter A. Cordero and Maribel Cordero, shall recover from Petitioner, Collier County, Florida, the total sum of Eighteen Thousand Eighteen Dollars and No/100 ($18,018.00), for all attorney’s fees and attorney litigation costs in this case, including fees related to monetary and non-monetary benefits and supplemental proceedings, if any. 3. Respondents, Peter A. Cordero and Maribel Cordero, shall recover from Petitioner, Collier County, Florida, the total sum of Eight Thousand Nine Hundred Forty-One Dollars and No/100 ($8,941.00), for all expert fees and costs, associated with the acquisition of Parcel 1339FEE, 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 Thirty-Eight Thousand Four Hundred Dollars and No/100 ($38,400.00), as payment for the acquisition of Parcel 1339FEE, 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 Eighty-One Thousand Five Hundred Fifty-Nine Dollars and No/100 ($81,559.00), representing the total sum due for the acquisition of Parcel 1339FEE, attorney’s fees, costs, expert fees and costs, by issuing a check payable to Trust Account of Policastro Law Group, LLC, and mailing it to Anthony Policastro, Esq., c/o Policastro Law Group, 1700 N McMullen Booth Rd Ste C5, Clearwater, FL 33759-2129. 6. Collier County's initial construction of the subject project shall substantially conform with the County's 90% construction plans, filed with the Court on March 25, 2025. The 90% construction plans provide for two travel lanes on Vanderbilt Beach Road; however, the right- of-way footprint is sufficient to accommodate up to a six-lane road design on Vanderbilt Beach Page 4473 of 4682 [25-CA-224/1964372/1] Road for which Respondents are entitled to compensations. Such compensation, if any, if reflected in the herein Final Judgment. No additional compensation shall be due to the Respondents for the actual future widening of Vanderbilt Beach Road up to four-lanes or six-lanes, including related roadway improvements to Vanderbilt Beach Road. 7. This Order disposes of all claims arising out of the taking of Parcel 1339FEE 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 27, 2025, 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 6438, Page 3064 of the Public Records of Collier County, Florida be dismissed as to Parcel 1339FEE. 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. 12. Respondents, Fifth Third Bank, NA and Rob Stoneburner, Collier County Tax Collector, are dismissed from this lawsuit as to Parcel 1339FEE. Page 4474 of 4682 [25-CA-224/1964372/1] Exhibit “A” Page 4475 of 4682 AERIAL – PARCEL 1339FEE (VANDERBILT BEACH RD EXT (PH 2) PROJECT NO. 60249 12th Ave NE PARCEL 1339FEE / Page 4476 of 4682