Backup Documents 03/24/2026 Item #16K 1 ORIGINAL DOCUMENTS CHECKLIST & ROUTING SLIP
TO ACCOMPANY ALL ORIGINAL DOCUMENTS SENT TO 1 6 K I
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#I 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 lines#1 through#2,complete the checklist,and forward to the County Attomey 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
KTT f m� 3/7/
4. BCC Office Board of County DK by MB
Commissioners [s] *)-(
5. Minutes and Records Clerk of Court's Office94-1- z
PRIMARY CONTACT INFORMATION J
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 Madison Bird Phone Number 2939
Contact/Department
Agenda Date Item was Agenda Item Number
Zy
Approved by the BCC 3 Zd ! /'l
Type of Document(s) Number of Original
Attached Aq�t�,e.,i- Documents Attached
PO number or account �! p
number if document is p( S� aMa:t G Cal � to
to be recorded Soso.. Vi I irt4A1 CJ CeI(. t.3.v
INSTRUCTIONS & CHECKLIST
Initial the Yes column or mark"N/A" in the Not Applicable column,whichever is Yes N/A(Not
appropriate. (Initial) Applicable)
. 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 3j2Y and all changes made during N/A is not
the meeting have been incorporated in the attached document. The County Attorney )--thni an option for
Office has reviewed the changes,if applicable. I this line.
9. Initials of attorney verifying that the attached document is the version approved by the N/A is not
BCC, all changes directed by the BCC have been made, and the document is ready for the Rz-rifilb an option fog
Chairman's signature. this line.
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 (hereinafter referred to as the "Agreement") is
entered into and made on this ate` day of lv\(t rch , 2026, by and between
ANTONIETTA IANNELLI-COLBOURN, hereinafter referred to as "Plaintiff," and COLLIER
COUNTY BOARD OF COUNTY COMMISSIONERS, hereinafter referred to as"County."
WITNESSETH:
WHEREAS, Plaintiff 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 Antonietta Jannelli-
Colbourn v. Collier County Board of Commissioners, Case No. 24-CA-2582 (hereinafter referred
to as the "Lawsuit"); and
WHEREAS,Plaintiff 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 unaccrued. to the incident described
or allegations made in the complaint filed in the Lawsuit; and,
WHEREAS,Plaintiff 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, Plaintiff and
County agree as follows:
1. Plaintiff 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 seven thousand five hundred dollars and no cents ($7,500.00) and other valuable
consideration, the receipt and adequacy of which is hereby acknowledged by Plaintiff, Plaintiff
agrees to dismiss the Lawsuit with Prejudice as it relates to the County. Plaintiff shall dismiss the
case with prejudice within ten (10)days of receipt of the settlement funds.
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, Plaintiff, on behalf of
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herself, her 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, attomy'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, Plaintiff 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. Plaintiff 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. Plaintiff and the County recognize and acknowledge that this Agreement
memorializes 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 Plaintiff or the County.
7. Plaintiff 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, Plaintiff and the County agree
that all underlying causes of action or claims of Plaintiff against the County have been extinguished
by this Agreement and that the sole remedy for breach of this Agreement shall be for specific
performance of the terms and conditions of this Agreement. In this regard, Plaintiff and the County
[24-CA-2582/2003941/1] 2
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further agree that the sole venue for any such action shall be in the Twentieth Judicial Circuit in
and for Collier County, Florida in Naples, Florida.
10. Plaintiff agrees 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 Plaintiff brought or could have brought in the subject Lawsuit. The Plaintiff agrees
to be solely responsible for complete payment of all other obligations out of the settlement
proceeds, including any future medical bills.
I I. The Plaintiff hereby agrees 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, Plaintiff and the County have signed and sealed this
Agreement and Release as set forth below. r—o«usgn.dby:
By: QtratinitAta, lan.wt,W� —(AllieuytA,
Antonse een
tettarannclli-Colbourn, Plaintiff
STATE OF FLORIDA
COUNTY OF COLLIER
The foregoing instrument was acknowledged before me by means of_physical presence
27th February
or x online notarization, this ` day of _ . 2026, by Antonietta lannelli-
Colbourn.
UocuSgnN by.. J
_ «t*►�i— _ — RICHARD WELDON I A a %JAL
Aft. Notary Public•State of Florida
' a f • Commission R HH 357984 l (, ignature o otary Public-State of Florida
' o'rrto My Comm.Expires Apr 14,2627
Bonded through Nattona Notary Assn. Richard weldon
(Print,Type,or Stamp Commissioners
Name of Notary Public)
_Personally Known OR x Produced Identification
Passport
Type of Identification Produced: .
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AS TO COUNTY:
ATTEST:
d .' ,�,3'1CIi'S'*�1i;K. KINZEL,Clerk BOARD OF COUNTY COMMISSIONERS
,� OF COLLIER COUNTY, FLORIDA
Y ff
;4 ' i' _, ' )-\'"-,, : ,,, /a
, t/ r' By: r —
,"rj `"}`.,.. ;� Attest as to Chairman's Dan Kowal,Chairperson
*Ff i `J,, ,, signature only
' Date: 2 1 202-6 Date: 3f 2`11 26 _
Appr. - as to form and 1-gality
dovqouti
'onald T.Tomasko
Assistant County Attorney
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