10/04/2022 Settlement Agreement UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO: 4:21-cv-10099-GAYLES/TORRES
LAURA GOODMAN,
Plaintiff,
V.
MONROE COUNTY,
Defendant.
ACKNOWLEDGMENT OF SETTLEMENT
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:
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
lawsuit, Defendant, MONROE COUNTY, FLORIDA agrees to pay the Plaintiff, LAURA
GOODMAN, $25,000.00, subject to municipal approval in the usual manner. Defendant will
also pay the cost of mediation.
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.
From these settlement proceeds,Plaintiff agrees to satisfy all related and outstanding liens.
The settlement drafts shall be made payable to Remer& Georges-Pierre, PLLC - Tax ID 4
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.
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.
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Attorney for Plaintiff Plaintiff
Jonathan cH. Rallel� Monroe County
Attorney for Defendant Defendant
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Authorized Rep for Defendant