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Agenda 01/13/2026 Item #16K10 (Stipulated Final Judgment for the taking of Parcel 1295FEE required for the Vanderbilt Beach Road Extension Project No. 60249)1/13/2026 Item # 16.K.10 ID# 2025-5122 Executive Summary Recommendation to approve a Stipulated Final Judgment in the amount of $190,000 plus $45,971 in statutory attorney and experts’ fees and costs for the taking of Parcel 1295FEE required for the Vanderbilt Beach Road Extension Project No. 60249. OBJECTIVE: To settle full compensation for the taking of Parcel 1295FEE 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 1295FEE 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, southerly boundary of the property and is approximately 0.38 acres in extent. The parent tract is improved with a single-family home owned by Suarez Property Enterprise LLC, 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 $80,100 including severance damages. The property owner’s initial demand was $321,400 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 $190,000 plus $38,709 in statutory attorney’s fees, and $7,262 in expert fees and costs, for a total of $235,971. 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 $80,100 for its good faith estimate of value. Funds for the balance of $156,041, 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. P1295FEE - Joint Motion for Stipulated Final Judgment(1) 2. Aerial - Parcel 1295FEE Page 12045 of 14062 [25-CA-217/1989103/1] 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-217 vs. Parcel 1295FEE Suarez Property Enterprise LLC, a Florida Limited Liability Company; PAZ Contracting Group LLC aka PAZ Contracting Group Inc; Paulino F. Llanes; Noam Levy; Miri Armoza; Unknown Tenants; Mortgage Electronic Registration Systems, Inc; Nikole Richards; PennyMac Loan Services, LLC; Admirals Bank NKA 42 North Private Bank; US Department of Housing and Urban Development; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ JOINT MOTION FOR ENTRY OF A STIPULATED FINAL JUDGMENT AS TO PARCEL 1295FEE Petitioner, Collier County, Florida, together with Respondent, Suarez Property Enterprise LLC, a Florida Limited Liability Company (hereinafter “Suarez Property Enterprise LLC”), by and through the undersigned counsel, hereby respectfully moves this Court for the entry of the foregoing Stipulated Final Judgment as to Parcel 1295FEE 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/ JOHN M. LEROUX__ JOHN M. LEROUX, ESQ. Florida Bar No. 773166 LeRoux Law 13065 W. Linebaugh Ave., Ste 101 Tampa, FL 33626 Telephone: (727) 712-1137 COUNSEL FOR RESPONDENT John@lerouxlaw.com Pleadings@lerouxlaw.com Sherrice@lerouxlaw.com Page 12046 of 14062 [25-CA-217/1989103/1] 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 ________________ 2026. BY: _______________________________ SALLY A. ASHKAR, ESQ. Page 12047 of 14062 [25-CA-217/1989103/1] 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-217 vs. Parcel 1295FEE Suarez Property Enterprise LLC, a Florida Limited Liability Company; PAZ Contracting Group LLC aka PAZ Contracting Group Inc; Paulino F. Llanes; Noam Levy; Miri Armoza; Unknown Tenants; Mortgage Electronic Registration Systems, Inc; Nikole Richards; PennyMac Loan Services, LLC; Admirals Bank NKA 42 North Private Bank; US Department of Housing and Urban Development; and Rob Stoneburner, Collier County Tax Collector, Respondents. ______________________________________________/ STIPULATED FINAL JUDGMENT AS TO PARCEL 1295FEE THIS CAUSE, having come before this Court upon the Joint Motion made by Petitioner, Collier County, Florida, and Respondent, Suarez Property Enterprise LLC, by and through counsel, for the entry of a Stipulated Final Judgment as to Parcel 1295FEE 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. Respondent, Suarez Property Enterprise LLC, shall recover from Petitioner, Collier County, Florida, the total sum of One Hundred Ninety Thousand Dollars and No/100 ($190,000.00), for Parcel 1295FEE, as full payment for the property interest taken, including business damages, if any, in connection with said Parcel. 2. Respondent, Suarez Property Enterprise LLC, shall recover from Petitioner, Collier County, Florida, the total sum of Thirty-Eight Thousand Seven Hundred Nine Dollars and Page 12048 of 14062 [25-CA-217/1989103/1] No/100 ($38,709.00), for all attorney fees and attorney litigation costs in this case, including fees related to monetary and non-monetary benefit. 3. Respondent, Suarez Property Enterprise LLC, shall recover from Petitioner, Collier County, Florida, the total sum of Seven Thousand Two Hundred Sixty-Two Dollars and No/100 ($7,262.00), for all expert fees and costs, associated with the acquisition of Parcel 1295FEE, 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 Eighty Thousand One Hundred Dollars and No/100 ($80,100.00), as payment for the acquisition of Parcel 1295FEE, 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 One Hundred Fifty-Five Thousand Eight Hundred Seventy-One Dollars and No/100 ($155,871.00), representing the total sum due for the acquisition of Parcel 1295FEE, attorney’s fees and costs, and expert fees and costs, by issuing a check payable to LeRoux Law Trust Account, and mailing it to John M. LeRoux, Esq., LeRoux Law, 13065 W. Linebaugh Ave., Ste 101, Tampa, FL 33626. 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; 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. Page 12049 of 14062 [25-CA-217/1989103/1] 7. This Order disposes of all claims arising out of the taking of Parcel 1295FEE 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 May 9, 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 1885 of the Public Records of Collier County, Florida be dismissed as to Parcel 1295FEE. 10. Respondents, PAZ Contracting Group LLC aka PAZ Contracting Group Inc; and Rob Stoneburner, Collier County Tax Collector are dismissed from this action as to Parcel 1295FEE. 11. This Court reserves jurisdiction to enforce the terms of this Stipulated Final Judgment. 12. This Stipulated Final Judgment is to be recorded in the Official Records of Collier County, Florida. Page 12050 of 14062 [25-CA-217/1989103/1] Exhibit “A” Page 12051 of 14062 AERIAL – PARCEL 1295FEE (VANDERBILT BEACH RD EXT (PH 2) PROJECT NO. 60249 PARCEL 1295FEE / Page 12052 of 14062