11/22/2016 AgreementIN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT
IN AND FOR MONROE COUNTY, FLORIDA
Board of County Commissioners, of
Monroe County, Florida
a political subdivision Case No.: 14 -CA -P -415 -P
of the State of Florida
Plaintiff,
V.
Gilbert L. Sanchez, and
Dalia Sanchez
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 5th day of October, 2016, at 10:00 a.m.
the parties hereby stipulate and agree to the following matters and/or issues:
The parties agree to an amended fine of $25.00 per day, for 1,461.00 days, which
equals $36,525.00, and a one -time fine of $15,000.00. The County's hard costs remain to
be determined, and will be paid by Defendants. The Defendants will pay, in addition to
the $15,000.00 down payment, the County's hard costs, all within thirty (30) days of
execution of this agreement. The remainder of the fine, which is $36,525.00, will be paid
in twelve (12) equal installments, beginning sixty (60) days after the execution pf this
agreement.
All parties hereto understand and agree that Plaintiffs counsel will present the
above terms as a settlement option to the Plaintiff, and that the validity of this agreement
is subject to the approval of the Board of County Commissioners. If it is not so approved
as an acceptable settlement, then this agreement shall be null and void.
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 't) day of October, 2016.
Signatum-QUlaintiff s Counsel, Steven Williams, Esq.
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Signature of Defendant's Counsel, Robert on; Jx. , Esq.
Signature of Defendant, Dalia Sanchez