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Agenda 09/23/2025 Item #16K 6 (Approve a Stipulated Final Judgment in the amount of $90,000 plus $26,142 in statutory attorney and experts’ fees and costs for the taking of Parcel 1340FEE required for the Vanderbilt Beach Road Extension Project No. 60249)9/23/2025 Item # 16.K.6 ID# 2025-3617 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $90,000 plus $26,142 in statutory attorney and experts’ fees and costs for the taking of Parcel 1340FEE required for the Vanderbilt Beach Road Extension Project No. 60249. OBJECTIVE: To settle full compensation for the taking of Parcel 1340FEE 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 1340FEE 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 0.17 acres in extent. The parent tract includes a single-family home and associated improvements and is owned by Robert Sierra and Adriana Sierra. The parent tract contains 1.14 acres of gross land area, which will be reduced to .97 acres after the acquisition. An aerial photograph of the subject property is attached. The County’s appraiser estimated full compensation at $38,100 including severance damages. The property owner’s initial demand was $150,600 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 $90,000 plus $17,127 in statutory attorney’s fees, $9,015 in expert fees and costs, for a total of $116,142. 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 $38,100 for its good faith estimate of value. Funds for the balance of $78,042 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. P1340FEE FINAL Joint Motion for Stipulated Final Judgment 2. Aerial - Parcel 1340FEE Page 3466 of 3896 [25-CA-225/1972093/1] _______________________________ 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 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-225 vs. Parcel 1340FEE Roberto T. Sierra; Adriana Sierra; Mortgage Electronic Registration Systems, Inc; Lawrence W. Zimmer III; Alice B. Zimmer; Linda Nizzardo; 3 Palm Electric LLC; Unknown tenant(s); Michael Baglino; Allison Duran; Joel Symonds; Brenda Symonds; Alfred Blake; Island Paradise Builders LLC; Brenda Symonds PA; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 1340FEE Petitioner, Collier County, Florida, together with Respondents, Roberto T. Sierra and Adriana Sierra, and Respondent Mortgage Electronic Registration Systems, Inc., by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1340FEE attached hereto as Exhibit “1”. __________/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 ROBERTO AND ADRIANA SIERRA tony@policastrolaw.com eric@policastrolaw.com yadi@policastrolaw.com Page 3467 of 3896 [25-CA-225/1972093/1] _/s/ Jason Duggar__________________ JASON DUGGAR, ESQ. Florida Bar No. 083813 GhidottiBerger LLP 10800 Biscayne Blvd, Ste. 201 Miami, FL 33161 COUNSEL FOR MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. jduggar@ghidottiberg.com Telephone: (305) 501-2808 Ext. 1214 Fax: (954) 780-5578 Page 3468 of 3896 [25-CA-225/1972093/1] 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 3469 of 3896 [25-CA-225/1972093/1] 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-225 vs. Parcel 1340FEE Roberto T. Sierra; Adriana Sierra; Mortgage Electronic Registration Systems, Inc; Lawrence W. Zimmer III; Alice B. Zimmer; Linda Nizzardo; 3 Palm Electric LLC; Unknown tenant(s); Michael Baglino; Allison Duran; Joel Symonds; Brenda Symonds; Alfred Blake; Island Paradise Builders LLC; Brenda Symonds PA; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 1340FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, Collier County, Florida, and Respondents, Roberto T. Sierra and Adriana Sierra, and Respondent Mortgage Electronic Registration Systems, Inc., by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1340FEE 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, Roberto T. Sierra and Adriana Sierra, shall recover from Petitioner, Collier County, Florida, the total sum of Ninety Thousand Dollars and No/100 ($90,000.00), subject to apportionment, if any, for Parcel 1340FEE, as full payment for the property interest taken, including business damages, if any, in connection with said Parcel. Page 3470 of 3896 [25-CA-225/1972093/1] 2. Respondents, Roberto T. Sierra and Adriana Sierra, shall recover from Petitioner, Collier County, Florida, the total sum of Seventeen Thousand One Hundred Twenty-Seven Dollars and No/100 ($17,127.00), for all attorney fees and attorney litigation costs in this case, including fees related to monetary and non-monetary benefits and supplemental proceedings, if any. 3. Respondents, Roberto T. Sierra and Adriana Sierra, shall recover from Petitioner, Collier County, Florida, the total sum of Nine Thousand Fifteen Dollars and No/100 ($9,015.00), for all expert fees and costs, associated with the acquisition of Parcel 1340FEE, 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 One Hundred Dollars and No/100 ($38,100.00), as to Parcel 1340FEE, 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 Seventy-Eight Thousand Forty-Two Dollars and No/100 ($78,042.00), representing the balance due for the acquisition of Parcel 1340FEE of Fifty-One Thousand Nine Hundred Dollars and No/100 ($51,900.00), 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. That upon the receipt and clearing of the funds pursuant to Paragraph 5 above, the Policastro Law Group, shall issue a check in the sum of One Thousand Two Hundred Seventy- Three Dollars and 35/100 ($1,273.35), from its Trust Account payable to the Trust Account of Page 3471 of 3896 [25-CA-225/1972093/1] GhidottiBerger, and mail it to Jason Dugar, Esq., GhidottiBerger, 10800 Biscayne Blvd, Suite 201, Miami, FL 33161, as attorney for Mortgage Electronic Registration Systems, Inc., in satisfaction of the attorney’s fees and costs of Mortgage Electronic Registration Systems, Inc. in this matter, to be applied as follows: a. The sum of Five Hundred Seven Dollars and 90/100 ($507.90) shall be applied to GhidottiBerger attorneys fee and cost Invoice Number 968039, dated May 28, 2025, in satisfaction of same. b. The sum of Seven Hundred Sixty-Five Dollars and 45/100 ($765.45) shall be applied to GhidottiBerger attorneys fee and cost Invoice Number 972097, dated June 26, 2025, in satisfaction of same. 7. 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 26, 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 Road for which Respondents are entitled to compensation. Such compensation, if any, is 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. 8. This Order disposes of all claims arising out of the taking of Parcel 1340FEE that have or could have been asserted in this cause. 9. 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 6, 2025, and the deposit of money heretofore made, is approved, ratified, and confirmed. Page 3472 of 3896 [25-CA-225/1972093/1] 10. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book 6438, Page 3234 of the Public Records of Collier County, Florida be dismissed as to Parcel 1340FEE. 11. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 121. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. 13. Respondent, Rob Stoneburner, Collier County Tax Collector, is dismissed from this lawsuit as to Parcel 1340FEE. Exhibit “A” Page 3473 of 3896 AERIAL – PARCEL 1340FEE (VANDERBILT BEACH RD EXT (PH 2) PROJECT NO. 60249 10th Ave NE PARCEL 1340FEE / Page 3474 of 3896