Item R10 R.10
Coty f � ,�� ,' BOARD OF COUNTY COMMISSIONERS
�� Mayor David Rice,District 4
The Florida Keys � Mayor Pro Tem Craig Cates,District 1
y Michelle Coldiron,District 2
James K.Scholl,District 3
Ij Holly Merrill Raschein,District 5
County Commission Meeting
October 19, 2022
Agenda Item Number: R.10
Agenda Item Summary #11236
BULK ITEM: No DEPARTMENT: County Attorney's Office
TIME APPROXIMATE: STAFF CONTACT: Cynthia Hall (305) 292-3470
N/A
AGENDA ITEM WORDING: Approval of settlement in the case of Laura Goodman v. Monroe
County, Florida, Case No. 21-cv-10099.
ITEM BACKGROUND: This is a proposed settlement in the employment discrimination case of
Laura Goodman v. Monroe County. In her complaint, Ms. Goodman, who was previously employed
in the Code Compliance department as a Collections Facilitator and who was terminated during her
probationary period, alleged discrimination and retaliation. The action is pending in federal court in
the Southern District of Florida, Case No. 21-cv-10099.
The key terms of the settlement are as follows: The County will pay to the Plaintiff $25,000 plus
$800 for the plaintiff's share of costs for a mediation in return for a general release of all claims by
the Plaintiff and dismissal of the case with prejudice, conditional upon approval by the BOCC.
There is no admission of liability.
IF THIS ITEM IS APPROVED IN BULK, THERE WILL BE NO NEED TO HOLD THE
CLOSED SESSION THAT IS ALSO SCHEDULED FOR OCTOBER 19, 2022 IN THIS
MATTER.
PREVIOUS RELEVANT BOCC ACTION: N/A
CONTRACT/AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATION: Approval.
DOCUMENTATION:
Settlement Agreement Goodman
Packet Pg.4833
R.10
FINANCIAL IMPACT:
Effective Date: N/A
Expiration Date:
Total Dollar Value of Contract: N/A
Total Cost to County:
Current Year Portion:
Budgeted: Yes
Source of Funds:
CPI: N/A
Indirect Costs: N/A
Estimated Ongoing Costs Not Included in above dollar amounts:
Revenue Producing: If yes, amount:
Grant:
County Match:
Insurance Required: No.
Additional Details:
N/A
REVIEWED BY:
Cynthia Hall Completed 10/04/2022 3:39 PM
Bob Shillinger Completed 10/04/2022 3:44 PM
Budget and Finance Completed 10/04/2022 3:45 PM
Brian Bradley Completed 10/04/2022 3:48 PM
Lindsey Ballard Completed 10/04/2022 3:54 PM
Board of County Commissioners Pending 10/19/2022 9:00 AM
Packet Pg.4834
R.10.a
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO: 4:21-cv-10099-GAYLES/TORRES
LAURA GOODMAN,
Plaintiff,
V.
MONROE COUNTY,
Defendant. 0
ACKNOWLEDGMENT OF SETTLEMENT
U)
The captioned case was mediated via Zoom on October 4, 2022, with all parties and their -
respective counsel. The mediation resulted in a complete settlement of all claims for damages, and
the terms of that settlement are: 0
In full, final, and complete settlement of all claims (past and future) for
injuries/losses/damages sustained by Plaintiff and expenses incurred (and to be incurred in the
future)by or on behalf of Plaintiff as a direct or indirect result of the alleged claims asserted in this 'a
lawsuit, Defendant, MONROE COUNTY, FLORIDA agrees to pay the Plaintiff, LAURA 0
GOODMAN, $25,000.00, subject to municipal approval in the usual manner. Defendant will
also pay the cost of mediation.
a�
In exchange for the payments as set forth above, Plaintiff agrees to execute a full general
Release in favor of this Defendant. Defendant's Release shall be submitted to Plaintiff's counsel
on or before October 14, 2022.
a�
From these settlement proceeds,Plaintiff agrees to satisfy all related and outstanding liens. u
The settlement drafts shall be made payable to Remer& Georges-Pierre, PLLC - Tax ID 4 E
36-4623742
Defendant shall tender payment within fourteen (14)days after receiving both the executed
Release and an executed W-9 form from Plaintiff's counsel and the Board of County
Commissioners' approval of this settlement.
Each parry agrees to pay its own attorney's fees and costs except for the mediation fee.
Within 10 days after receiving the settlement draft, Plaintiff's counsel shall execute and file with
the Court a Stipulation for Dismissal of this action,with prejudice, in favor of this Defendant.
Packet Pg.4835
R.10.a
The Court retains jurisdiction to enforce the terms of this mediated settlement agreement.
This 2-page Acknowledgement of Settlement was read in its entirety before it was voluntarily
executed below by (or on behalf ofi all settling parties and by their respective counsel this 4rh Day
of October,_2022.
I ,iir,€nnri i(004,.x022144V7FI1C)
Attorney for Plaintiff Plaintiff
n L a v �t� 1 rc lei
Jonathan H. Ral Monroe County
0
Attorney for Defendant Defendant c
E
Authorized Rep for Defendant
4-
0
0
CL
CL
E
0
0
as
E
as
as
as
E
as
as
as
E
Packet Pg.4836