Backup Documents 11/10/2025 Item #16K 1 ORIGINAL DOCUMENTS CHECKLIST & ROUTING SLIP 1 6 K 1
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO
THE BOARD OF COUNTY COMMISSIONERS OFFICE FOR SIGNATURE
Print on pink paper. Attach to original document. The completed routing slip and original documents are to be forwarded to the County Attorney Office
at the time the item is placed on the agenda. All completed routing slips and original documents must be received in the County Attorney Office no later
than Monday preceding the Board meeting.
** ROUTING SLIP**
Complete routing lines#1 through#2 as appropriate for additional signatures,dates,and/or information needed. If the document is already complete with the
exception of the Chairman's signature,draw a line through routing)ines#I through#2,complete the checklist,and forward to the County Attorney Office.
Route to Addressee(s) (List in routing order) Office Initials Date
1.
2. (Enter your Dept here)
3. County Attorney Office County Attorney Office
aileb 1110
4. BCC Office Board of County BS by MB
Commissioners [s] I
5. Minutes and Records Clerk of Court's Office `I f? ;:5
PRIMARY CONTACT INFORMATION •
Normally the primary contact is the person who created/prepared the Executive Summary. Primary contact information is needed in the event one of the
addressees above may need to contact staff for additional or missing information.
Name of Primary Staff A4trdisun Bi,d Phone Number }3�
Contact/Department koSa 1/rllgrrev.l n2.1
Agenda Date Item was Agenda Item Number
Approved by the BCC I1/(0 12.5
Type of Document(s) Number of Original
Attached '5e f(-,ns,.4- Documents Attached
PO number or account
number if document is
to be recorded
INSTRUCTIONS & CHECKLIST
Initial the Yes column or mark"N/A" in the Not Applicable column,whichever is Yes N/A(Not
appropriate. (Initial) Applicable)
1. Does the document require the chairman's signature?(stamped unless otherwise stated) MB
2. Does the document need to be sent to another agency for additional signatures? If yes, N/A
provide the Contact Information(Name;Agency;Address; Phone)on an attached sheet.
3. Original document has been signed/initialed for legality. (All documents to be signed by MB
the Chairman,with the exception of most letters,must be reviewed and signed by the
Office of the County Attorney.)
4. All handwritten strike-through and revisions have been initialed by the County Attorney MB
Office and all other parties except the BCC Chairman and the Clerk to the Board.
5. The Chairman's signature line date has been entered as the date of BCC approval of the MB
document or the final negotiated contract date whichever is applicable.
6. "Sign here"tabs are placed on the appropriate pages indicating where the Chairman's MB
signature and initials are required.
7. In most cases (some contracts are an exception),the original document and this routing slip N/A
should be provided to the County Attorney Office at the time the item is uploaded to the
agenda. Some documents are time sensitive and require forwarding to Tallahassee within a
certain time frame or the BCC's actions are nullified. Be aware of your deadlines!
8. The document was approved by the BCC on Itilu and all changes made during ',A is not
the meeting have been incorporated in the attached document. The County Attorney / N option for
Office has reviewed the changes, if applicable. t 1'j s line. _
9. Initials of attorney verifying that the attached document is the version approved by the A is not
BCC,all changes directed by the BCC have been made, and the document is ready for the .,,Nmi, e'option fox
Chairman's signature. �G���l A s It
I:Forms/County Forms/BCC Forms/Original Documents Routing Slip WWS Original 9.03.04;Revised 1.26.05;2.24.05; 11/30/12;4/22/16;9/10/21
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• SETTLEMENT AGREEMENT
THIS SETTLEMENT AGREEMENT (her Mailer referred to as the ".Agreement")"is
entered into and made on this VS4:day of. Qi2 D , 2025, by and between LILIMA.i2
ASCANIO; REYNALDO ASCANIO, VALERIE ASCANIO, LILIMAR ASCANIO AS
PARENT OF (a minor child), hereinafter collectively referred to as
"Plaintiffs," and COLLIER COUNTY HOARD OF COUNTY COMMISSIONERS, hereinafter
referred to as "County."
WITNESSETE: •
WHEREAS, Plaintiffs filed a lawsuit against the County in the Circuit Court for the
Twentieth Judicial Circuit in and for Collier County, Florida, in the case styled Lt/imar Ascanio,
Reynaldo Ascanto, Lilimar Ascania as Parent, Lilirnar Ascanio as Parent v. Collier 'County
Board of Commissioners, Case No,24-CA-2515(hereinafter referred to as the 'Lawsuit"); and
WHEREAS, Plaintiffs and the County, without either party admitting any liability or
fault, desires to settle the Lawsuit and any and all disputes that arise from, relate or refer in any
way, whether directly or indirectly, known or unknown, accrued or unaccmi d, to the incidents
described or allegations made in the complaint fled in the Lawsuit; and,
WHEREAS, Plaintiffs and the County desire to reduce the settlement to a writing so that
it shall be binding upon both parties' respective owners, principals, elected officials, officers,
employees, ex-employees, agents, attorneys, representatives, insurers of the County, successors,
assigns, heirs, departments, and agencies,
NOW, THEREFORE, in consideration of the mutual covenants, promises and
consideration set forth in this Agreement, and with the intent to be legally bound, Plaintiffs and
County agree as follows:
1. Plaintiffs and the County adopt and incorporate the foregoing recitals, sometimes
referred to as "Whereas Clauses," by reference into this Agreement.
2. In consideration of the resolution of all disputes or claims arising from or .
referring or relating in any way, whether directly or indirectly, to the Lawsuit, and for and in
consideration of the sum of twenty-five thousand dollars and no cents ($25,000.00) and other
valuable consideration, the receipt and adequacy of which is hereby acknowledged by Plaintiffs,
Plaintiffs agree to dismiss the Lawsuit with Prejudice as it relates to the County,
[24-CA-2515/1977236/1i 1
•
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3. In consideration of the resolution of the Lawsuit, and for other good and valuable
consideration, the receipt and adequacy of which is hereby acknowledged, Plaintiffs, on behalf of
themselves, their attorneys, agents, representatives, heirs, successors and assigns; hereby
expressly releases•and forever discharges the County, as well as its owners, principals, elected
officials, officers, employees, ex-employees, agents, attorneys, contractors, representatives,
successors, assigns, insurers of the County, heirs, departments, and agencies, from any and all
claims,demands, causes of actions, damages, costs, liens, attorney's fees, expenses, medical bills
and obligations of any kind or nature whatsoever, that she has asserted or could have asserted in
the Lawsuit or that arise from or relate or refer in any way, whether directly or indirectly,
accrued or unaccrued, known or unknown, to the Lawsuit or any incident, event or allegation
referred to in the complaint in the Lawsuit.
4. Notwithstanding anything that may be to the contrary in Paragraph 3 of this
Agreement, Plaintiffs and the County agree that either of them (as well as any other persons or
entities intended to be bound) shall, in the event of any breach, retain the right to enforce the
terms and Conditions of this Agreement.
5. Plaintiffs and the County acknowledge and agree that this Agreement is intended
to and shall be binding upon their respective owners, principals, elected officials, officers,
employees, ex-employees, agents, attorneys, representatives, insurers of the County, successors,
assigns, and heirs.
6, Plaintiffs and the County recognize and acknowledge that this Agreement
mennbrializes and states a settlement of disputed claims and nothing in this Agreement shall be
construed to be an admission of any kind, whether of fault, liability, or of a particular policy or
procedure,on the part of either Plaintiffs or the County,
7. Plaintiffs and the County acknowledge and agree that this Agreement is the
product of mutual negotiation and no doubtful or ambiguous language or provision in this
Agreement is to be construed against any party based upon a claim that the party drafted the
ambiguous provision or language or that the party was intended to be benefited by the
ambiguous provision or language,
• 8. This Agreement may be amended only by a written instrument specifically
referring to this Agreement and executed with the same formalities as this Agreement,
9. In the event of an alleged breach of this Agreement, Plaintiffs and the County
agree that all underlying causes of action or claims of Plaintiffs against the County have been
[24-CA-2515/1977236/1] 2
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extinguished by this Agreement and that the sole remedy for breach of this Agreement shall he
for specific performance of the terms and conditions of this Agreement, In this regard, Plaintiffs
and the County limber agree that the sole venue for Any such action shall he in the Twentieth
Judicial Circuit in and for Collier County,Florida in Naples, Florida,
10. Plaintiffs agree to use the proceeds of the settlement funds for the payment and
satisfaction of all liens,past and future medical bills, attorney fees, and all other expenses,costs,
debts, or losses whatsoever, arising out of or in any way connected to the incident described in
the Lawsuit, which Plaintiffs brought or could have brought in the subject Lawsuit, The
Plaintiffs agree to be solely responsible for complete payment of all other obligations out of the
settlement proceeds,including any future medical bills.
11. The Plaintiffs hereby agree to indemnify and hold harmless the County from any
and all claims and/or liens and/or subrogated interests, including but not limited to worker's
compensation liens, health Insurance liens, Medicaid /Medicare liens, Social Security and any
• and all attorney's liens and charging liens herein.
12, This Agreement shall be governed by the laws of the State of Florida.
IN WITNESS WHEREOF, Plaintiffs and the County have signed and sealed this
Agreement and Release as set forth below.
By:
Litimar ,Plaintiff
By:
Re o Ascania, Plaintiff
By: Va a `b"e"
Valerie Asa io,Plaintiff
By:
L ' caoio Plaintiff, on behalf
of a Minor Child
STATE OF FLORIDA
COUNTY OF COLLIE?1t
[24-CA-2515/1977236 l 3
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The foregoing instrument was ac' ncwled , b 'fwe by means of _ physical
presence or online notarization, this day of _ �, 2025,by Idlimar Ascanio,
Reynaldo Ascanio, Valerie Ascanio, and ilimar Ascanio on miff of a minor
child.
NI
;;a"' ° % tAYNE18ARMSOUZA (Signature of Natal*"'tic to of Florida
,; t MY COMMISSION it HH 5b8278
,�Q� ;A• EXPIRES:JUNI 27,2028
Print_L,Q•4)1)Q. S b Q‘RAILA &MA
{ ype, or Stamp Commissioners
Name of Notary Public)
Personally Known OR__Produced Identification
Type of Identification Produced: Y1 �
AS TO COUNTY:
AT.I ; T: •.. •
7.
CRYSTAL . KTI/4E,Clerk BOARD OF COUNTY COMMISSIONERS
: : OF COL ER COUNTY,FLORIDAB 4 E�r
13
ttest as to Chairman's 13 rt Saunders, C airperson
•
�� ' .ill .•.. i re only
Date' ��.. _.._. Date: L/Jlo/7.5
Appr as to orm d legality
Ronald T. Tornasko
Assistant County Attorney
[24-CA-2515/1977236/1.1 4