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Agenda 11/10/2025 Item #16K 5 (Stipulated Final Judgment in the amount of $142,000 plus $31,134 in statutory attorney fees, expert fees, and costs for the taking of Parcel 1334FEE required for the Vanderbilt Beach Road Extension Project No. 60249.)11/10/2025 Item # 16.K.5 ID# 2025-4596 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $142,000 plus $31,134 in statutory attorney fees, expert fees, and costs for the taking of Parcel 1334FEE required for the Vanderbilt Beach Road Extension Project No. 60249. OBJECTIVE: To settle full compensation for the taking of Parcel 1334FEE 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 1334FEE 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 0.41 acres in extent. The parent tract is improved with a single-family home and associated improvements owned by Yaneisy Montelier and Alain Delgado. The parent tract contains 2.73 acres of gross land area, which will be reduced to 2.32 acres after the acquisition. An aerial photograph of the subject property is attached. The County’s appraiser estimated full compensation at $74,300 including severance damages. The property owner’s initial demand was $239,500 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 Judgment reflects a negotiated compensation amount of $142,000 plus $22,572 in statutory attorney’s fees and $8,562 expert fees, for a total of $173,134. The settlement does not include supplemental attorney’s fees, which are often associated with apportionment proceedings that occur after settlement funds are deposited with the Court. If any such fees are claimed, a separate item will be presented to the Board for approval of payment. Pursuant to Chapter 73, Florida Statutes, the taking authority is responsible for payment of supplemental attorney’s fees. 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 $74,300 for its good faith estimate of value. Funds for the balance of $99,004, including $170 Clerk’s 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. – CMG RECOMMENDATION(S): 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. P1334FEE - Joint Motion for Stipulated Final Judgment 2. Aerial - Parcel 1334FEE Page 5065 of 6525 11/10/2025 Item # 16.K.5 ID# 2025-4596 Page 5066 of 6525 [25-CA-215/1978895/1] 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-215 vs. Parcel: 1334FEE Sean Grant; Sharon Grant; Mortgage Electronic Registration Systems, Inc., Carmen Julia Reyes Michel; Luis D. Perez; Luis Ramon Perez; Beatriz Mesa; Unknown Tenants; Linda Alavez; Francisco Alavez; Mid-State Trust IX, operating by and through Wilmington Trust FSB not in its individual capacity but solely as the Trustee of Mid-State Trust IX, N/K/A Wilmington Trust National Association; Yaneisy Montelier; Alain Delgado; Manuel Lopez; Maria Eugenia Lopez; Midland Funding, LLC; Naples HMA LLC d/b/a Physicians Regional Medical Center – Collier; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 1334FEE Petitioner, Collier County, Florida, together with Respondents, Yaneisy Montelier and Alain Delgado, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1334FEE 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/ MICHAEL R. WHITT ____ MICHAEL R. WHITT, ESQ Florida Bar No. 725020 Hahn Loeser & Parks, LLP 2400 First Street, Suite 300 Fort Myers, FL 33901-2904 Telephone: (239) 337-6754 COUNSEL FOR RESPONDENTS mwhitt@hahnlaw.com kzamzow@hahnlaw.com Page 5067 of 6525 [25-CA-215/1978895/1] 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 5068 of 6525 [25-CA-215/1978895/1] 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-215 vs. Parcel: 1334FEE Sean Grant; Sharon Grant; Mortgage Electronic Registration Systems, Inc., Carmen Julia Reyes Michel; Luis D. Perez; Luis Ramon Perez; Beatriz Mesa; Unknown Tenants; Linda Alavez; Francisco Alavez; Mid-State Trust IX, operating by and through Wilmington Trust FSB not in its individual capacity but solely as the Trustee of Mid-State Trust IX, N/K/A Wilmington Trust National Association; Yaneisy Montelier; Alain Delgado; Manuel Lopez; Maria Eugenia Lopez; Midland Funding, LLC; Naples HMA LLC d/b/a Physicians Regional Medical Center – Collier; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 1334FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, Collier County, Florida, and Respondents, Yaneisy Montelier and Alain Delgado, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1334FEE 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, Yaneisy Montelier and Alain Delgado, shall recover from Petitioner, Collier County, Florida, the total sum of One Hundred Forty-Two Thousand Dollars and No/100 ($142,000.00), for Parcel 1334FEE, subject to apportionment, as full payment for the property interest taken, including business damages, if any, in connection with said Parcel. Page 5069 of 6525 [25-CA-215/1978895/1] 2. Respondents, Yaneisy Montelier and Alain Delgado, shall recover from Petitioner, Collier County, Florida, the total sum of Twenty-Two Thousand Five Hundred Seventy-Two Dollars and No/100 ($22,572.00), for all attorney’s fees and attorney litigation costs in this case, including fees related to monetary and non-monetary benefits, but not including supplemental attorney’s fees which may be awarded for apportionment issues. 3. Respondents, Yaneisy Montelier and Alain Delgado, shall recover from Petitioner, Collier County, Florida, the total sum of Eight Thousand Five Hundred Sixty-Two Dollars and No/100 ($8,562.00), for all expert fees and costs, associated with the acquisition of Parcel 1334FEE, 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 Seventy-Four Thousand Three Hundred Dollars and No/100 ($74,300.00), as payment for the acquisition of Parcel 1334FEE, 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 Thirty-One Thousand One Hundred Thirty-Four Dollars and No/100 ($31,134.00), representing the total sum due for the attorney’s fees and costs, and expert fees and costs, by issuing a check payable to Hahn Loeser & Parks, LLP Trust Account, and mailing it to Michael R. Whitt, Esq., c/o Hahn Loeser & Parks, LLP, 2400 First Street, Suite 300, Fort Myers, FL 33901 for distribution. 6. Within thirty (30) days from the entry of this Order, Petitioner, Collier County, Florida, shall deposit the sum of Sixty-Seven Thousand Seven Hundred Dollars and No/100 Page 5070 of 6525 [25-CA-215/1978895/1] ($67,700.00), into the Court Registry, representing the total balance due for the acquisition of Parcel 1334FEE as outlined above. 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 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 to Respondent for the 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 1334FEE 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 June 20, 2025, and the deposit of money heretofore made, is approved, ratified, and confirmed. 10. The Notice of Lis Pendens filed in this cause and recorded in Official Record Book 6438, Page 1798 of the Public Records of Collier County, Florida be dismissed as to Parcel 1334FEE. 11. Respondent, Rob Stoneburner, Collier County Tax Collector is dismissed from this action as to Parcel 1334FEE. 12. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment, and any apportionment issues. 13. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. Page 5071 of 6525 [25-CA-215/1978895/1] Exhibit “A” Page 5072 of 6525 AERIAL – PARCEL 1334FEE (VANDERBILT BEACH RD EXT (PH 2) PROJECT NO. 60249 PARCEL 1334FEE 10th Ave NE / Page 5073 of 6525