Case 13-CA-1113-K 06/21/2017RELEASE OF CLAIM
AND INDEMNIFICATION A REEMENT
KNOW ALL MEN BY THESE PRESENTS:
That JOSE SANTIAGO, hereinafter referred to as "first party ", for and in consideration of
the sum of FIFTY TWO THOUSAND FIVE HUNDRED DOLLARS AND NO /CENTS
($52,500) or other valuable consideration, received from or on behalf of MONROE COUNTY and
the FLORIDA MUNICIPAL INSURANCE TRUST, their agents, and employees, hereinafter
referred to as "second parties ", the receipt whereof is hereby acknowledged.
HEREBY irrevocably remises, releases, acquits, satisfies, and forever discharges the said
second parties, which includes the Florida Municipal Insurance Trust, their agents, servants, and
employees, of and from all, and all manner of action and actions, cause or causes of action, suits,
attorneys' fees and costs, specialties, covenants, contracts, controversies, agreements, promises,
variances, trespasses, damages, judgments, executions, claims and demands whatsoever, in law or
in equity, which said first party ever had, now has, or which any personal representative, successor,
heir or assign of said first party, hereafter can, shall or may have, against said second parties,
including the Florida Municipal Insurance Trust, for, upon or by reason of any matter, cause or thing
whatsoever, arising out of that incident which occurred on October 13, 2009, at, in, or near Big
Coppitt Fire Department Station 9, Emerald Drive, Key West, FL 33040, Monroe County,
Florida, and to any cause of action raised in, or that could have been raised in, or arising out of the
filing and prosecution of the litigation described as Jose Santiago v. Monroe County Case Number
13 -CA -1 113 -K.
I represent that all medical bills, hospital bills, disability and wage losses, including any
subrogation rights or liens for the payment of same by any third party, including any Medicare and
Medicaid liens or rights for reimbursement, which arose out of the incident sued upon in the
aforementioned litigation have been paid in full or will be settled with the proceeds of this
settlement. I SPECIFICALLY UNDERTAKE AND AGREE TO INDEMNIFY the second parties
for any claims, demands, subrogation rights or liens that may be asserted against the second parties
for the above mentioned expenses or losses of the first party.
It is understood and agreed to by the parties that this settlement is a compromise ofa doubtful
and disputed claim and the payment is not to be construed as an admission of liability on the part of
the second party(ies), by whom liability is expressly denied.
I have carefully read the Release of Claim and understand its terms, operation, and effect.
IN WITNESS WHEREOF, I have hereunto set m hand and seal this
Y � day of
, 2017.
Release of Claim
and Indemnification Agreement
Page 2
Signed, sealed and delivered
in the presence of:
JOSE SANTI
STATE OF FLORIDA )
) SS:
COUNTY OF MONROE)
I HEREBY CERTIFY that on this day, before me, an officer duly authorized in the State
aforesaid and in the County aforesaid to take acknowledgments, personally appeared Jose Santiago
li*who is known to me or Q who has produced a valid driver's licence or identification card, and
who did take an oath, executed the foregoing instrument and that he acknowledged before me that
he executed same.
!�
WITNESS my hand and official seal in the County and State last aforesaid this 3 day
of 1 , 2017.
NOTARY PUBLIC, ST E OF 1
FLORIDA AT L R
My Commission Expires:
a Notary Public State of Florid Claudia Balmaceda
b. My Commission FF 190786
Expires 01/25/2019
This Instrument Prepared By:
CHRISTOPHER J. STEARNS, ESQ.
Johnson, Anselmo, Murdoch.
Burke, Piper & Hochman, P.A.
2455 East Sunrise Blvd., Suite 1000
Fort Lauderdale, Fl. 33304
Telephone: (954) 463 -0100
Fla. Bar No. 557870
MONROE COUNTY ATTORNEY
APPROVED A TO FORM
C RIS A BROSIO
ASSIS ANT COUNTY ATTORNEY
Date: / 7
IN THE CIRCUIT COURT OF THE
16"" JUDICIAL CIRCUIT IN AND
FOR MONROE COUNTY, FLORIDA
CASE NO.: 2013 -CA -1 113 -K
JOSE SANTIAGO,
Plaintiff,
VS.
MONROE COUNTY, FLORIDA,
Defendant.
STIPULATION FOR DISMISSAL WITH PREJUDICE
IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel for the
respective parties herein, that the claims of Plaintiff, JOSE SANTIAGO, against Defendant, MONROE
COUNTY, have been amicably resolved, and shall be dismissed with prejudice, with the respective parties
herein to bear their own costs and attorneys` fees.
DATED this day of
2017.
GARCIA LAW FIRM
Attorneys for Plaintiff
TRIAL ATTORNEYS
515 Whitehead Street
Key West, FL 33040
M
NATHALIA MELLIES
Fla. Bar No. 087398
JOHNSON ANSELMO, MURDOCH,
BURKE, PIPER & HOCHMAN, P.A.
Attorneys for(30UNTY
2455 East S6ise Blvd., Suite 1000
Fort Lauderdald. FL 33304
USTOPHER J. STEARNS
Bar Ni 557870