Case No. 17-CA-000561-P RELEASE OF CLAIM
AND INDEMNIFICATION AGREEMENT
KNOW ALL MEN BY THESE PRESENTS:
That FILIPPOS KELARIS, hereinafter referred to as "first party ", for and in consideration
of the sum of ONE HUNDRED THOUSAND DOLLARS AND NO /CENTS ($100,000) or other
valuable consideration, received from or on behalf of MONROE COUNTY, hereinafter referred
to as "second party ", the receipt whereof is hereby acknowledged.
HEREBY irrevocably remises, releases, acquits, satisfies, and forever discharges the said
second parties, and their agents, servants, and employees, of and from all, and alI 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, for, upon or by reason of any matter, cause or thing
whatsoever, arising from that accident which Plaintiff alleges occurred on or about October 4, 2016,
at or near the intersection of Lake Shore Drive and Maderia Drive, Key Largo, 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 Filippos Kelaris v. Monroe County,
et al, Case Number 17 -CA- 000561 -P. This Release specifically excludes all claims against
GEICO GENERAL INSURANCE COMPANY.
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
party for any claims, demands, subrogation rights or liens that may be asserted against the second
party 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 of a 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.
n
IN WITNESS WHEREOF, I have hereunto set my hand and seal this 7 day of
aae."', 2018.
Signed, sealed and delive--:" -
in the presence • f:
i
.."-Adia Zi<
� S • -_--• • IS WITNESS
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 Filippos
Kelaris' who is known to me or Cl 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 `tip day
of 0V , 2018.
NOTARY PUBLIC, STATE OF
FLORIDA AT LARGE
My Commission Expires:
IVia).„1 ."--
4 • .,i7 CHRISTINE MENDEZ
4 ... ': Notary Public - State of Florida t
W p Commission &GG 246515 I
This Instrument Prepared By: o. My Comm. Expires Aug 7, 2022
4 Banded through National Notary Assn.
E. BRUCE JOHNSON, ESQ.
Johnson, Anselmo, Murdoch,
Burke, Piper & Hochman, P.A.
2455 East Sunrise BIvd., Suite 1000
Fort Lauderdale, FL 33304
Telephone: (954) 463 -0100
Fla. Bar No. 262137 •
MONROE COUNTY ATTORNEY
4PP VEDA O Fe RM
CHRIS AMBROSIO
ASSISTA T COU TY ATTORNEY
Date: ( ° 7O / g