Agenda 04/14/2026 Item #16K11 (Offer of Judgment for the taking of Parcel 1345FEE required for the Vanderbilt Beach Road Extension Project No. 60249, Case No. 25-CA-225)4/14/2026
Item # 16.K.11
ID# 2026-839
Executive Summary
Recommendation to authorize the making of an Offer of Judgment in the amount of $260,000.00 to Respondents, Joel
Symonds; Brenda Symonds; Island Paradise Builders, LLC; and Brenda Symonds PA, in the lawsuit styled Collier
County, Florida v. Roberto T. Sierra, et al.; Case No. 25-CA-225, for the taking of Parcel 1345FEE required for the
Vanderbilt Beach Road Extension Project No. 60249.
OBJECTIVE: To approve and authorize the making of an Offer of Judgment pursuant to 73.032 Fla. Stat. and Rule
1.442, Fla.R.Civ.P., to Respondents, Joel Symonds; Brenda Symonds; Island Paradise Builders LLC; and Brenda
Symonds PA, in the amount of $260,000.00 as full compensation for the condemnation of Parcel 1345FEE, Collier
County, Florida v. Roberto T. Sierra, et al; Case No. 25-CA-225, for the taking of Parcel 1345FEE required for the
Vanderbilt Beach Road Extension Project No. 60249.
CONSIDERATIONS: On February 6, 2025, an eminent domain action was filed for the acquisition of property for the
Vanderbilt Beach Road Extension Project No. 60249. Parcel 1345FEE was acquired as a fee simple acquisition. On
May 6, 2025, a Stipulated Order of Taking was entered by the Circuit Court as to Parcel 1345FEE, and on May 16,
2025, the good faith estimate of value in the amount of $78,900 was deposited into the Court registry, thereby vesting
title in the parcels in Collier County.
The Offer of Judgment, a copy of which is attached, offers the property owners of this Parcel, Joel Symonds and Brenda
Symonds, the sum of $260,000.00 as full compensation for the property taken, including any severance damages,
business damages, damages to the remainder, costs to cure and interest, but excluding statutory attorney fees, costs, and
expert fees. This figure accounts for the basis of the appraised value and the potential risks and costs of proceeding to
trial. The making of the Offer of Judgment will require the property owners to carefully assess their claims for
compensation. Joel Symonds and Brenda Symonds have thirty days from the date of serving the offer to accept. If Joel
Symonds and Brenda Symonds accept, the County will be required to deposit an additional $181,100.00 into the
registry, and the total sum of funds on deposit will be paid to Joel Symonds and Brenda Symonds by Stipulated Final
Judgment of the court. The County will also be obligated to pay statutory attorney fees, costs, and the expert fees
associated with the taking of Parcel 1345EE. If Joel Symonds and Brenda Symonds reject the offer and fail to recover
more than $260,000.00 for Parcel 1345FEE, either through settlement or jury verdict, the County will not be required to
pay any costs incurred by Joel Symonds and Brenda Symonds after the date of the offer’s rejection. This would include
any expert witness fees, such as appraisal fees. Island Paradise Builders LLC and Brenda Symonds, PA, have been
identified in the action as a potential business interest associated with the subject parcel. The proposed Offer of
Judgment includes compensation for any potential business damages, in addition to all other compensation and damages
that may otherwise be awarded.
The County Attorney’s Office has reviewed all considerations in making an Offer of Judgment and has calculated in
good faith this offer of full compensation for the property interests taken. This office considers the terms of the Offer of
Judgment to be reasonable.
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 $78,900 for its good faith estimate of value. Funds for the balance
of $181,100.00, plus attorney’s fees and costs and expert fees, 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. –
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4/14/2026
Item # 16.K.11
ID# 2026-839
SAA
RECOMMENDATION(S): To approve the attached Offer of Judgment and authorize the payment of funds as stated
herein.
PREPARED BY: Robert Bosch, Manager, Manager ROW Acquisition, Operations and Performance Management
ATTACHMENTS:
1. Offer of Judgement P1345FEE
Page 3016 of 3203
[25-CA-225/2011305/1]
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
Collier County, Florida, a political Subdivision
of the State of Florida,
Plaintiff,
Case No. 25-CA-225
vs. Parcel 1345FEE
Roberto T. Sierra; Adriana Sierra; Mortgage Electronic
Registration Systems, Inc; Lawrence W. Zimmer III;
Alice B. Zimmer; Linda Nizzardo; 3 Palm Electric LLC;
Unknown tenant(s); Michael Baglino; Allison Duran;
Joel Symonds; Brenda Symonds; Alfred Blake; Island
Paradise Builders LLC; Brenda Symonds PA; and
Rob Stoneburner, Collier County Tax Collector,
Respondents.
_________________________________________________/
OFFER OF JUDGMENT
Petitioner, Collier County, Florida, by and through the undersigned counsel, hereby makes
this Offer of Judgment to Respondents, Joel Symonds; Brenda Symonds; Island Paradise Builders
LLC; and Brenda Symonds PA, and states:
1. This offer is made pursuant to §73.032, Florida Statutes and Rule 1.442, Fla.R.Civ.P.
2. This offer is made to settle all pending claims of Respondents for all claims of any
nature in this action, excluding only attorney fees and costs and expert costs, in the amount of Two
Hundred Sixty Thousand Dollars and No/100 ($260,000.00).
3. The Offer of Judgment shall be deemed rejected unless accepted by filing both a
written acceptance and the written offer with the Court within 30 days after service of the offer. In
accordance with §73.032, Florida Statutes, upon proper filing of both the offer and acceptance, the
Court shall enter judgment thereon. A rejection of the offer terminates the offer.
4. The Offer is to resolve all compensation and damages that would otherwise be awarded
Page 3017 of 3203
[25-CA-225/2011305/1]
to the Respondents in a final judgment in this action.
5. The Petitioner may withdraw this Offer of Judgment in writing served on Respondents
before a written acceptance is served on Petitioner. Once withdrawn in this manner, the offer is
void.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing Offer of Judgment was furnished by e-mail to
counsel for Respondents, Boatman Ricci., on this ____ day of _______________ 2026.
BY: __________________________________
COLLEEN M. GREENE, ESQ.
Florida Bar No. 502650
SALLY A. ASHKAR, Esq.
Florida Bar No. 1007665
Collier County Attorney’s Office
3299 East Tamiami Trail, Suite 800
Naples, FL 34112
Telephone: (239) 252-8400
Facsimile: (239) 252-6912
COUNSEL FOR PETITIONER
Colleen.Greene@collier.gov
Sally.Ashkar@collier.gov
Sheri.Malcolm@collier.gov
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