15-CA-560-P/Mediation Agreementr f 'A
IN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT
IN AND FOR MONROE COUNTY, FLORIDA
BOARD OF COUNTY COMMISIONERS
OF MONROE COUNTY, Case No.: 15-CA-550-P
Plaintiff,
V.
KEY LARGO SERVICE STATION, LLC
Defendants
MEDIATION AGREEMENT
THIS ACTION having come to mediation as agreed to by all counsel and being
heard by Mediator EUGENE KYLE, ESQ. on the 22nd day of February, 2016, at 9:00
a.m. the parties hereby stipulate and agree to the following matters and/or issues:
The Plaintiffs will accept the sum of $33,002.61 (THIRTYTHREE THOUSAND
TWO AND 61/100 DOLLARS), in toto, inclusive of fines and costs regarding the
property known as 98210 Overseas Highway, Key Largo, Florida. The Defendant will be
able to make SIX (6) equal monthly payments of FIVE THOUSAND FIVE HUNDRED
AND 44/100 DOLLARS ($5,500.44) beginning on July 1,2016 until the above sum of
$33,002.61 is paid in full. The Mediation fees are a total of EIGHT HUNDRED
DOLLARS ($800.00). The Defendant will be responsible for paying one half (1/2) of the
fees, or $400.00 by 3/15/15. The Mediator will submit a Statement for Services to
Monroe County for the other $400.00. This agreement is subject to and becomes effective
only upon the approval and ratification of the Monroe County Board of Commissioners,
and will be null and void if it is not so approved and ratified.
The parties further agree:
1. There is good and valuable consideration for this agreement.
2. The parties have entered into this agreement knowingly, freely, and
voluntarily, having determined that they have adequate information upon
which to make informed decisions and having decided that it is in their best
interests to amicably resolve this action.
3. The Mediator has given no legal advice to either party.
4. Time is of the essence.
5. Each party will cooperate with the other and execute any documents necessary
or convenient to the effectuation of this agreement.
6. Except as may otherwise be specifically stated herein, this is the entire
agreement between the parties to this date. There are no promises or
understandings except as set out herein. Any prior understandings are
repudiated.
7. Neither party is under coercion or duress. Neither has been forced into this
agreement or threatened in any way.
8. Neither party knows of any fact or circumstance, which would cause this
agreement to be void or unenforceable.
9. Each party intends to be bound by this agreement and provides that it is
binding on their heirs, beneficiaries, successors and assigns.
10. This agreement is effective upon signing.
All matters raised at the Mediation Conference remain privileged and
confidential, unless otherwise agreed to by all parties and ordered by the Court.
Dated this -2 2 A day of February, 2016.
Signature oglaintiff's Counsel, Steven Williams, Esq.
Signature of ant's Counsel, Ignacio M. Urbieta
Signature of Defendant, Guillermo Urbieta