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Agenda 09/09/2025 Item #16K 3 (Stipulated Final Judgment - Parcel 1350FEE required for the Vanderbilt Beach Road Extension Project #60249)9/9/2025 Item # 16.K.3 ID# 2025-2831 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $127,500 plus $28,362 in statutory attorney and experts’ fees and costs for the taking of Parcel 1350FEE required for the Vanderbilt Beach Road Extension Project No. 60249. OBJECTIVE: To settle full compensation for the taking of Parcel 1350FEE 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 1350FEE 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, northerly boundary of the property and is approximately 0.34 acres in extent. The parent tract includes one single-family home and associated site improvements owned by Gladys Gomez and Nancy Agras and contains 2.27 acres of gross land area, which has been reduced to 1.93 acres after the acquisition. An aerial photograph of the subject property is attached. The County’s appraiser estimated full compensation at $67,400 including severance damages. The property owner’s initial demand was $224,800 plus attorney’s fees and expert fees and costs. The parties participated in mediation and initially came to an impasse, but reached an agreement post-mediation. The attached Stipulated Order of Taking and Final Judgment reflects a negotiated compensation amount of $127,500 plus $20,064 in statutory attorney’s fees, and $8,298 in expert fees and costs, for a total of $155,862. 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 $67,400 for its good faith estimate of value. Funds for the balance of $88,632, which includes the Clerk’s $170.00 deposit fee, 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 majority vote for approval. – SAA 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. P1350FEE - Signed Joint Motion for Stipulated Final Judgment(1) 2. Aerial - Parcel 1350FEE Page 2275 of 2661 [25-CA-226/1967795/1] 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-226 vs. Parcel 1350FEE Michael DeMattia; Kristen DeMattia; Louise M. Teger-McKoy; Robert John McKoy; Mortgage Electronic Registration Systems, Inc; PLOCO 4, LLC, a Florida limited liability company; Unknown Tenant(s); Sherry A. Nigro AKA Sherry A. Connor Nigro; Stephen R. Nigro; Select Portfolio Servicing, Inc; Green Corridor Property Assessment Clean Energy (PACE) District; Mad Batter Pet Bakery LLC; American Brokers Holdings, LLC, a Delaware limited liability company; FIG 20, LLC; Gladys M. Gomez; Nancy A. Agras; Kris Organics LLC; Exquisite Home Watch, LLC; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 1350FEE Petitioner, Collier County, Florida, together with Respondents, Gladys M. Gomez and Nancy A. Agras, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1350FEE 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/ JOHN M. LEROUX _ JOHN M. LEROUX, ESQ. Florida Bar No. 773166 LeRoux Law 13065 W. Linebaugh Ave., Ste 101 Tampa, FL 33626 Telephone: (727) 712-1137 COUNSEL FOR RESPONDENTS John@lerouxlaw.com Pleadings@lerouxlaw.com Sherrice@lerouxlaw.com Page 2276 of 2661 [25-CA-226/1967795/1] 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: _______________________________ SALLY A. ASHKAR, ESQ. Page 2277 of 2661 [25-CA-226/1967795/1] 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-226 vs. Parcel 1350FEE Michael DeMattia; Kristen DeMattia; Louise M. Teger-McKoy; Robert John McKoy; Mortgage Electronic Registration Systems, Inc; PLOCO 4, LLC, a Florida limited liability company; Unknown Tenant(s); Sherry A. Nigro AKA Sherry A. Connor Nigro; Stephen R. Nigro; Select Portfolio Servicing, Inc; Green Corridor Property Assessment Clean Energy (PACE) District; Mad Batter Pet Bakery LLC; American Brokers Holdings, LLC, a Delaware limited liability company; FIG 20, LLC; Gladys M. Gomez; Nancy A. Agras; Kris Organics LLC; Exquisite Home Watch, LLC; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 1350FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, Collier County, Florida, and Respondents, Gladys M. Gomez and Nancy A. Agras, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1350FEE 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, Gladys M. Gomez and Nancy A. Agras, shall recover from Petitioner, Collier County, Florida, the total sum of One Hundred Twenty-Seven Thousand Five Hundred Dollars and No/100 ($127,500.00), for Parcel 1350FEE, as full payment for the property interest taken, including business damages, if any, in connection with said Parcel. Page 2278 of 2661 [25-CA-226/1967795/1] 2. Respondents, Gladys M. Gomez and Nancy A. Agras, shall recover from Petitioner, Collier County, Florida, the total sum of Twenty Thousand Sixty-Four Dollars and No/100 ($20,064.00), for all attorney fees and attorney litigation costs in this case, including fees related to monetary and non-monetary benefits. 3. Respondents, Gladys M. Gomez and Nancy A. Agras, shall recover from Petitioner, Collier County, Florida, the total sum of Eight Thousand Two Hundred Ninety-Eight Dollars and No/100 ($8,298.00), for all expert fees and costs associated with the acquisition of Parcel 1350FEE, 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 Sixty-Seven Thousand Four Hundred Dollars and No/100 ($67,400.00), as payment for the acquisition of Parcel 1350FEE, 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 sum of Eighty-Eight Thousand Four Hundred Sixty-Two Dollars and No/100 ($88,462.00), representing the total sum due for the acquisition of Parcel 1350FEE, attorney’s fees and costs, and expert fees and costs, by issuing a check payable to LeRoux Law Trust Account, and mailing it to John M. LeRoux, Esq., LeRoux Law, 13065 W. Linebaugh Ave., Ste 101, Tampa, FL 33626. 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; however, the right-of-way footprint is sufficient to accommodate up to a six-lane road design. No additional compensation shall be due Page 2279 of 2661 [25-CA-226/1967795/1] to Respondents for the 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 1350FEE 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 May 19, 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 3927 of the Public Records of Collier County, Florida be dismissed as to Parcel 1350FEE. 10. Respondent, Rob Stoneburner, Collier County Tax Collector is dismissed from this action as to Parcel 1350FEE. 11. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 12. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. Page 2280 of 2661 [25-CA-226/1967795/1] Exhibit “A” Page 2281 of 2661 AERIAL – PARCEL 1350FEE (VANDERBILT BEACH RD EXT (PH 2) PROJECT NO. 60249 10th Ave NE PARCEL 1350FEE / Page 2282 of 2661