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Agenda 12/09/2025 Item #16K 9 (Stipulated Final Judgment in the amount of $150,000 plus $36,412 in statutory attorney fees, expert fees, and costs for the taking of Parcel 1316FEE1 required for the Vanderbilt Beach Road Extension Project No. 60249)12/9/2025 Item # 16.K.9 ID# 2025-4808 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $13, 0,,, plus $29081y in statutorx attornex fees0 e’pert fees0 and costs for the taking of Parcel 1219FEE1 required for the Vanderbilt Beach Road E’tension Project No. 9, y86. OBJECTIVE4 : o settle full compensation for the taking of Parcel 1219FEE1 required for the construction of the Vanderbilt Beach Road E’tension Project No. 9, y86. CONSIDERATIONS4 Tn Julx 60 y, y80 the Board authoriOed0 via Resolution No. y, y8z1230 the condemnation of Parcel 1219FEE1 for the construction of road- ax0 drainage and utilitx improvements required for the e’pansion and e’tension of Vanderbilt Beach Road from 19th Street NE to Everglades Blvd. : he fee simple acquisition area consists of a strip taking along the rear0 northerlx boundarx of the propertx and is appro’imatelx , .29 acres in e’tent. : he parent tract is improved - ith a singlezfamilx home and associated improvements o- ned bx 5 onfort wherelus and Brunette wherelus. : he parent tract contains y.23 acres of gross land area0 - hich - ill be reduced to 1.66 acres after the acquisition. An aerial photograph of the subject propertx is attached. : he wountxGs appraiser estimated full compensation at $C309, , including severance damages. : he propertx o- nerGs initial demand - as $y9802, , plus attornexGs fees and e’pert fees and costs. : he parties participated in mediation and reached an agreement subject to approval bx the Board of wountx wommissioners. : he attached Stipulated Final Judgment reflects a negotiated compensation amount of $13, 0,,, plus $y8033y in statutorx attornexGs fees and $110U9, e’pert fees0 for a total of $1U9081y. Staff recommends approval of this Stipulated Final Judgment since a better result is not anticipated at trial. Mpon approval0 the wountx AttornexGs Tffice - ill file the Joint 5 otion and Stipulated Final Judgment - ith the wircuit wourt. : his item is consistent - ith the wollier wountx strategic plan objective to design and maintain an effective transportation sxstem to reduce traffic congestion and improve the mobilitx of our residents and visitors. FISCAL IMPACT4 wountx is entitled to a credit of $C309, , for its good faith estimate of value. Funds for the balance of $11, 0U1y0 are available in the Vanderbilt Beach Road E’tension Project wapital Fund0 Project 9, y86. : he primarx funding source for the acquisition of right of - ax is through Road 7mpact Fee I istrict Funds D2, 6, 0 2, 610 2, 6y0 2, 620 2, 680 2, 63( in the Vanderbilt Beach Road from 19th to Everglades Project D9, y86(. Should impact fees not be sufficient0 the secondarx funding source - ill be Road wonstruction ) as : a’ Fund D2, U2( and : ransportation wapital Fund D2, U1(. GROWTH MANAGEMENT IMPACT4 : here is no gro- th management impact associated - ith this action. LEGAL CONSIDERATIONS4 : his item is approved as to form and legalitx and requires a majoritx vote for Board approval. – w5 ) RECOMMENDATION(S)4 : o approve the attached Joint 5 otion and Stipulated Final Judgment and authoriOe the paxment of funds as stated herein. PREPARED BY4 Robert Bosch0 5 anager0 5 anager RTW Acquisition0 Tperations and Performance 5 anagement ATTACHMENTS4 1. P1219FEE1 z Joint 5 otion for Stipulated Final Judgment y. Aerial z Parcel 1219FEE1 Page 7122 of 9661 [25-CA-218/1984887/1] 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-218 vs. Parcel: 1316FEE1 Monfort Cherelus; Brunette Cherelus; Jacqueline Roque De Escobar; Mortgage Electronic Registration Systems, Inc., Sunshine Way Investments LLC, a Florida limited liability company; Thomas E. Madigan; Suntrust Bank NKA Truist Bank; U.S. Small Business Administration; Trois Etoiles, LLC; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 1316FEE1 Petitioner, Collier County, Florida, together with Respondents, Monfort Cherelus and Brunette Cherelus, by and through undersigned counsel, hereby respectfully move this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1316FEE1 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@collier.gov Sally.Ashkar@collier.gov Sheri.Malcolm@collier.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 CHERELUS tony@policastrolaw.com eric@policastrolaw.com yadi@policastrolaw.com Page 7123 of 9661 [25-CA-218/1984887/1] 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: _______________________________ COLLEEN M. GREENE, ESQ. Page 7124 of 9661 [25-CA-218/1984887/1] 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-218 vs. Parcel: 1316FEE1 Monfort Cherelus; Brunette Cherelus; Jacqueline Roque De Escobar; Mortgage Electronic Registration Systems, Inc., Sunshine Way Investments LLC, a Florida limited liability company; Thomas E. Madigan; Suntrust Bank NKA Truist Bank; U.S. Small Business Administration; Trois Etoiles, LLC; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 1316FEE1 THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, Collier County, Florida, and Respondents, Monfort Cherelus and Brunette Cherelus, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1316FEE1 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, Monfort Cherelus and Brunette Cherelus, shall recover from Petitioner, Collier County, Florida, the total sum of One Hundred Fifty Thousand Dollars and No/100 ($150,000.00), for Parcel 1316FEE1, as full payment for the property interest taken, including business damages, if any, in connection with said Parcel. 2. Respondents, Monfort Cherelus and Brunette Cherelus, shall recover from Petitioner, Collier County, Florida, the total sum of Twenty-Four Thousand Five Hundred Page 7125 of 9661 [25-CA-218/1984887/1] Fifty-Two Dollars and No/100 ($24,552.00), for all attorney fees and attorney litigation costs in this case, including fees related to monetary and non-monetary benefits. 3. Respondents, Monfort Cherelus and Brunette Cherelus, shall recover from Petitioner, Collier County, Florida, the total sum of Eleven Thousand Eight Hundred Sixty Dollars and No/100 ($11,860.00), for all expert fees and costs, associated with the acquisition of Parcel 1316FEE1, 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-Five Thousand Six Hundred Dollars and No/100 ($75,600.00), as payment for the acquisition of Parcel 1316FEE1, 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 One Hundred Ten Thousand Eight Hundred Twelve Dollars and No/100 ($110,812.00), representing the balance due for the acquisition of Parcel 1316FEE1, 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 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 Page 7126 of 9661 [25-CA-218/1984887/1] 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 1316FEE1 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 1952 of the Public Records of Collier County, Florida be dismissed as to Parcel 1316FEE1. 10. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 11. Respondents, Rob Stoneburner, Collier County Tax Collector, and Trois Etoiles, LLC, are dismissed from this action as to Parcel 1316FEE1. 12. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. Page 7127 of 9661 [25-CA-218/1984887/1] Exhibit “A” Page 7128 of 9661 AERIAL – PARCEL 1316FEE1 (VANDERBILT BEACH RD EXT (PH 2) PROJECT NO. 60249 PARCEL 1316FEE1 / Page 7129 of 9661