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Agenda 12/09/2025 Item #16K 4 (Stipulated Final Judgment in the amount of $131,000 plus $29,808 in statutory attorney and experts’ fees and costs for the taking of Parcel 1322FEE required for the Vanderbilt Beach Road Extension Project No. 60249)12/9/2025 Item # 16.K.4 ID# 2025-4795 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $131,000 plus $29,808 in statutory attorney and experts’ fees and costs for the taking of Parcel 1322FEE required for the Vanderbilt Beach Road Extension Project No. 60249. OBJECTIVE: To settle full compensation for the taking of Parcel 1322FEE 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 1322FEE 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 0.38 acres in extent. The parent tract is improved with a single-family home and is owned by Sean and Sharon Grant, and contains 2.5 acres of gross land area, which has been reduced to 2.12 acres after the acquisition. An aerial photograph of the subject property is attached. The County’s appraiser estimated full compensation at $65,800 including severance damages. The property owner’s initial demand was $218,500 plus attorney’s fees and expert fees and costs. The parties participated in mediation and reached an agreement. The attached Stipulated Final Judgment reflects a negotiated compensation amount of $131,000 plus $21,516 in statutory attorney’s fees, and $8,292 in expert fees and costs, for a total of $160,808. 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 $65,800 for its good faith estimate of value. Funds for the balance of $95,178, 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 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. P1322FEE - Joint Motion for Stipulated Final Judgment(1) 2. Aerial - Parcel 1322FEE Page 7080 of 9661 [25-CA-215/1984787/1] 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 1322FEE 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 1322FEE Petitioner, Collier County, Florida, together with Respondents, Sean Grant and Sharon Grant, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1322FEE 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 GRANT tony@policastrolaw.com eric@policastrolaw.com yadi@policastrolaw.com Page 7081 of 9661 [25-CA-215/1984787/1] 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 December 2025. BY: _______________________________ SALLY A. ASHKAR, ESQ. Page 7082 of 9661 [25-CA-215/1984787/1] 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 1322FEE 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 1322FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, Collier County, Florida, and Respondents, Sean Grant and Sharon Grant, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1322FEE 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, Sean Grant and Sharon Grant, shall recover from Petitioner, Collier County, Florida, the total sum of One Hundred Thirty-One Thousand Dollars and No/100 ($131,000.00), for Parcel 1322FEE, as full payment for the property interest taken, including business damages, if any, in connection with said Parcel. Page 7083 of 9661 [25-CA-215/1984787/1] 2. Respondents, Sean Grant and Sharon Grant, shall recover from Petitioner, Collier County, Florida, the total sum of Twenty-One Thousand Five Hundred Sixteen Dollars and No/100 ($21,516.00), for all attorney fees and attorney litigation costs in this case, including fees related to monetary and non-monetary benefits. 3. Respondents, Sean Grant and Sharon Grant, shall recover from Petitioner, Collier County, Florida, the total sum of Eight Thousand Two Hundred Ninety-Two Dollars and No/100 ($8,292.00), for all expert fees and costs, associated with the acquisition of Parcel 1322FEE, 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-Five Thousand Eight Hundred Dollars and No/100 ($65,800.00), as payment for the acquisition of Parcel 1322FEE, 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 Ninety-Five Thousand Eight Dollars and No/100 ($95,008.00), representing the balance due for the acquisition of Parcel 1322FEE, 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 7084 of 9661 [25-CA-215/1984787/1] 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. 7. This Order disposes of all claims arising out of the taking of Parcel 1322FEE 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 23, 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 1798 of the Public Records of Collier County, Florida be dismissed as to Parcel 1322FEE. 10. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 11. Respondent, Rob Stoneburner, Collier County Tax Collector, is dismissed from this action as to Parcel 1322FEE. 12. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. Page 7085 of 9661 [25-CA-215/1984787/1] Exhibit “A” Page 7086 of 9661 AERIAL – PARCEL 1322FEE (VANDERBILT BEACH RD EXT (PH 2) PROJECT NO. 60249 PARCEL 1322FEE 10th Ave NE / Page 7087 of 9661