HomeMy WebLinkAbout2011-072 A TRUE COPY
1 CERTIFICATION ON LAST PAGE
J . K . BARTON , CLERK
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY , FLORIDA
CIRCUIT CIVIL DIVISION
INDIAN RIVER COUNTY , FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
Case No . : 20091990 CA05
V . Parcel No . : 122 -Harbourt
MATTHEW STANLEY HARBOURT, JR. , et al .
Defendants .
MEDl<ATED SETTLEMENT AGREEMENT
At the Mediation Conference held on February 21 , 20115 the parties reached the
following Settlement Agreement :
1 . Petitioner will pay to Defendants, Matthew Stanley Harbourt, Jr. , and
Hilda C . Harbourt, the sum of $490, 000 . 00 in full settlement of all claims for
compensation from Petitioner whatsoever, including statutory interest and all claims
related to real estate and business damages, if any, but excluding attorney' s fees, experts '
fees , and costs . Said sum will be subject to claims of apportionment, if any. Petitioner is
entitled to a credit in the amount of $297 , 000 . 00, said amount having been previously
deposited in the Registry of the Court in this case by Petitioner . Upon the satisfaction of
the terms and conditions of this Settlement Agreement and the entry of the Stipulated
Final Judgment in this matter, Petitioner will deposit in the Registry of the Court the sum
of $ 193 ,000 . 00, representing the difference between the total settlement sum referenced
above and Petitioner' s previous deposit referenced above .
2 . In addition to the settlement sum referenced in Paragraph 1 , Petitioner will
pay to Defendants ' attorney $ 57 , 792 . 90 in full settlement and satisfaction of all attorney ' s
fees and attorney ' s litigation costs incurred by Defendants in this case , including all
attorney ' s fees and attorney' s litigation costs related to monetary and non-monetary
benefits, and supplemental proceedings , if any.
3 . In addition to the settlement s�zm� referenced u Paragraph I of t1.is
Settlement Agreement, Petitioner will pay to Defendants ' expert witnesses
$40, 000 . 00 in full settlement and satisfaction of all experts ' fees and costs incurred by
Defendants in this case .
A TRUE COPY
1 CERTIFICATION ON LAST PAGE
J . K . BARTON , CLERK
- � IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY , FLORIDA
CIRCUIT CIVIL DIVISION
INDIAN RIVER COUNTY, FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
Case No . : 20091990 CA05
V . Parcel No . : 122 -Harbourt
MATTHEW STANLEY HAR13OURT, JR. , et al .
Defendants .
MEDIATED SETTLEMENT AGREEMENT
At the Mediation Conference held on February 21 , 2011 , the parties reached the
following Settlement Agreement :
1 . Petitioner will pay to Defendants , Matthew Stanley Harbourt, Jr. , and
Hilda C . Harbourt, the sum of $490,000 . 00 in full settlement of all claims for
compensation from Petitioner whatsoever, including statutory interest and all claims
related to real estate and business damages , if any, but excluding attorney ' s fees, experts '
fees, and costs . Said sum will be subject to claims of apportionment, if any. Petitioner is
entitled to a credit in the amount of $297,000 . 00 , said amount having been previously
deposited in the Registry of the Court in this case by Petitioner. Upon the satisfaction of
the terms and conditions of this Settlement Agreement and the entry of the Stipulated
Final Judgment in this matter, Petitioner will deposit in the Registry of the Court the sum
of $ 193 ,000 . 00, representing the difference between the total settlement sum referenced
above and Petitioner' s previous deposit referenced above .
2 . In addition to the settlement sum referenced in Paragraph 1 , Petitioner will
pay to Defendants ' attorney $ 57 , 792 . 90 in full settlement and satisfaction of all attorney ' s
fees and attorney ' s litigation costs incurred by Defendants in this case, including all
attorney ' s fees and attorney' s litigation costs related to monetary and non-monetary
benefits, and supplemental proceedings , if any.
3 . In addition to the settlement sum. referenced in. Paragraph 1 of this
Settlement Agreement, Petitioner will pay to Defendants ' expert witnesses
$40 ,000 . 00 in full settlement and satisfaction of all experts ' fees and costs incurred by
Defendants in this case .
A TRUE COPY
CERTIFICATION ON LAST PAGE
J . K . BARTON , CLERK
ri
4 . This Settlement Agreement is subject to and conditioned upon final
approval by the Indian River County Board of County Commissioners on or before March
225 2011 . Petitioner ' s legal counsel and staff will recommend approval of this Agreement
to the Indian River County Board of County Commissioners .
5 . Counsel for Petitioner and Defendants will jointly submit to the Court
a mutually approved Stipulated Final Judgment containing the terms and conditions of
this Settlement Agreement within ten days following the final approval of this
Agreement by the Indian River County Board of County Commissioners ,
6 . As a condition of this settlement, Petitioner, at the time of construction of
the subject road project, at Petitioner' s expense, will construct a driveway connection to
Defendant ' s existing driveway on 66`h Avenue . As a condition of this settlement,
Petitioner, at the time of construction of the subject road project and at Petitioner' s
expense, will construct a twenty-four-foot wide driveway connection with a drop curb
design on 66a' Avenue to align with the median opening at or about the southern property
line of Defendants ' property. As a condition of this settlement, Petitioner, at the time of
construction of the subject road project and at Petitioner' s expense, will install a culvert
pipe and construct a twelve-foot-wide driveway connection with a drop curb design at or
about Station 503 on 37a' Street.
This Settlement Agreement, dated February 21 , 2011 , contains all of the agreements of
the parties .
Christopher R. Mora on behalf Defendant, Matthew Stanley Harbourt, Jr.
of Petitioner, Ind ' o ti
f
Anthony V . Policastro , Esq . Defendant, Hilda C . Harbourt
Attorney for Pet ' i ner % l
11
vv uliaul n. Le1-31acu, LSCy . 1512ut i.: . sixion, L:Sq . ( `
Attorney for Petitioner Attorney for De en s
William B . Smith, Esq. David ollowa , ts
Mediator Attorney for Defendants
A TRUE COPY
CERTIFICATION ON LAST PAGE
J . K . BARTON , CLERK
ri
4 . This Settlement Agreement is subject to and conditioned upon final
approval by the Indian River County Board of County Commissioners on or before March
225 2011 . Petitioner ' s legal counsel and staff will recommend approval of this Agreement
to the Indian River County Board of County Commissioners .
5 . Counsel for Petitioner and Defendants will jointly submit to the Court
a mutually approved Stipulated Final Judgment containing the terms and conditions of
this Settlement Agreement within ten days following the final approval of this
Agreement by the Indian River County Board of County Commissioners ,
6 . As a condition of this settlement, Petitioner, at the time of construction of
the subject road project, at Petitioner' s expense, will construct a driveway connection to
Defendant ' s existing driveway on 66`h Avenue . As a condition of this settlement,
Petitioner, at the time of construction of the subject road project and at Petitioner' s
expense, will construct a twenty-four-foot wide driveway connection with a drop curb
design on 66a' Avenue to align with the median opening at or about the southern property
line of Defendants ' property. As a condition of this settlement, Petitioner, at the time of
construction of the subject road project and at Petitioner' s expense, will install a culvert
pipe and construct a twelve-foot-wide driveway connection with a drop curb design at or
about Station 503 on 37a' Street.
This Settlement Agreement, dated February 21 , 2011 , contains all of the agreements of
the parties .
Christopher R. Mora on behalf Defendant, Matthew Stanley Harbourt, Jr.
of Petitioner, Ind ' o ti
f
Anthony V . Policastro , Esq . Defendant, Hilda C . Harbourt
Attorney for Pet ' i ner % l
11
vv uliaul n. Le1-31acu, LSCy . 1512ut i.: . sixion, L:Sq . ( `
Attorney for Petitioner Attorney for De en s
William B . Smith, Esq. David ollowa , ts
Mediator Attorney for Defendants
IN WITNESS WHEREOF , the undersigned have approved and executed this
Mediated Settlement Agreement on this 15 day of March 2011 .
BOARD OF COUNTY COMMISSIONERS
INDIAN RIVER COUNTY , FLORIDA
z y
e n
BY :
•• '� °°°° ob Solari Chairman
46NbCyn4coui5l �a�a
BCC Approved : March. 15 , 2011 , j
,
Approved : ; ;EtORIDA .
INDIAN RIVEA;EOUNTY
rHIS IS TO CERTIFY THAT THIS IS
A"TRUE AND. COKAECT COPY-OF
`T14F. ORIGINAL ON FILE INTHIS
1) FFICE `
By -; J! FF EY -K._SA OH, CLERK
Jos ep A . Baird sY F '� � ' a D . C .
County Administrator ` '
DATE
Attest : Jeffrey K . Barton , Clerk of Court
By :
�at 0--C�
Deputy Clerk
Approved as to for nd ga`I lufficiency
William K . DeBraal
Deputy County Attorney
IN WITNESS WHEREOF , the undersigned have approved and executed this
Mediated Settlement Agreement on this 15 day of March 2011 .
BOARD OF COUNTY COMMISSIONERS
INDIAN RIVER COUNTY , FLORIDA
z y
e n
BY :
•• '� °°°° ob Solari Chairman
46NbCyn4coui5l �a�a
BCC Approved : March. 15 , 2011 , j
,
Approved : ; ;EtORIDA .
INDIAN RIVEA;EOUNTY
rHIS IS TO CERTIFY THAT THIS IS
A"TRUE AND. COKAECT COPY-OF
`T14F. ORIGINAL ON FILE INTHIS
1) FFICE `
By -; J! FF EY -K._SA OH, CLERK
Jos ep A . Baird sY F '� � ' a D . C .
County Administrator ` '
DATE
Attest : Jeffrey K . Barton , Clerk of Court
By :
�at 0--C�
Deputy Clerk
Approved as to for nd ga`I lufficiency
William K . DeBraal
Deputy County Attorney
A TRUE COPY
1 CERTIFICATION ON LAST PAGE
J . K . BARTON , CLERK
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY , FLORIDA
CIRCUIT CIVIL DIVISION
INDIAN RIVER COUNTY , FLORIDA, a
political subdivision of the State of Florida,
Petitioner,
Case No . : 20091990 CA05
V . Parcel No . : 122 -Harbourt
MATTHEW STANLEY HARBOURT, JR. , et al .
Defendants .
MEDl<ATED SETTLEMENT AGREEMENT
At the Mediation Conference held on February 21 , 20115 the parties reached the
following Settlement Agreement :
1 . Petitioner will pay to Defendants, Matthew Stanley Harbourt, Jr. , and
Hilda C . Harbourt, the sum of $490, 000 . 00 in full settlement of all claims for
compensation from Petitioner whatsoever, including statutory interest and all claims
related to real estate and business damages, if any, but excluding attorney' s fees, experts '
fees , and costs . Said sum will be subject to claims of apportionment, if any. Petitioner is
entitled to a credit in the amount of $297 , 000 . 00, said amount having been previously
deposited in the Registry of the Court in this case by Petitioner . Upon the satisfaction of
the terms and conditions of this Settlement Agreement and the entry of the Stipulated
Final Judgment in this matter, Petitioner will deposit in the Registry of the Court the sum
of $ 193 ,000 . 00, representing the difference between the total settlement sum referenced
above and Petitioner' s previous deposit referenced above .
2 . In addition to the settlement sum referenced in Paragraph 1 , Petitioner will
pay to Defendants ' attorney $ 57 , 792 . 90 in full settlement and satisfaction of all attorney ' s
fees and attorney ' s litigation costs incurred by Defendants in this case , including all
attorney ' s fees and attorney' s litigation costs related to monetary and non-monetary
benefits, and supplemental proceedings , if any.
3 . In addition to the settlement s�zm� referenced u Paragraph I of t1.is
Settlement Agreement, Petitioner will pay to Defendants ' expert witnesses
$40, 000 . 00 in full settlement and satisfaction of all experts ' fees and costs incurred by
Defendants in this case .