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RESOLUTION NO.
A RESOLUTION AUTHORIZING THE DIRECTOR
OF FINANCE TO PAY TO CARIDAD VIERA AND
FRED VIERA, HER HUSBAND, THE SUM OF
THIRTY THOUSAND DOLLARS ($30,000.00),
WITHOUT THE ADMISSION OF LIABILITY,
IN FULL AND COMPLETE SETTLEMENT OF
ALL BODILY INJURY, PERSONAL INJURY,
PROTECTION LIENS, WORKER'S COMPENSA-
TION LIENS, CLAIMS AND DEtANDS AGAINST
THE CITY OF MIAMI AND UPON EXECUTION
OF A RELEASE RELEASING THE CITY FROM
ALL CLAIMS AND DEi1ANDS.
WHEREAS, Caridad Viera and Fred Viera, through Jeffrey
Allen Tew, Esq., of Tew, Spittler, Berger & Bluestein, their
attorneys, filed a claim against the City of Miami for alleged
bodily injury, personal injury, protection liens, and worker's
compensation liens, resulting from an accident involving a
City owned vehicle on November 5, 1980, at the intersection
of Southwest 1st Street and Southwest 15th Avenue, Miami,
Dade County, Florida; and
WHEREAS, the above claims have been investigated by the
Torts Division of the City Attorney's Office and in accordance
with Ordinance No. 8417, which creates the City of Miami
Self -Insurance Program, the said office recommends that
these claims be settled, without the admission of liability,
for the sum of Thirty Thousand Dollars ($30,000.00).
NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE
CITY OF MIAMI, FLORIDA:
Section 1. The Director of Finance is hereby authorized
to pay to Caridad Viera and Fred Viera, her husband, the sum of
Thirty Thousand Dollars ($30,000.00), without the admission of
liability, in full and complete settlement of all bodily injury,
personal injury, protection liens, worker's compensation liens,
claims and demands against the City of Miami, upon execution
of a Release releasing the City of Miami from bodily injury, personal
CITY COMMISSION
MEETING OF
JUL ; 1 1.982
11600" ft... 82-65
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injury, protection liens, worker's compensation liens and claims
and demands.
PASSED AND ADOPTED this 22ND day of JULY , 1982.
ATTES :
MA.T='Y HIRA_I
ACTING CITY CLERK
PREPARED AND APPROVED BY:
�T is J. R6berts
Assistant City Attorney
APPROVED Ac ' 4 L'^D"" AND CORRECTNESS:
Geor, F. Knox,'Jr.
City torneyc._
-2-
MAURICE A. FERRE
MAURICE A. FERRE
MAYOR
82-6i55_ .
69
To Honorable Members of July 7, 1982
j
'y C on
Settlement of Caridad Viera and -
Fred Viera, her husband, v.
The City of Miami
F. Knox, Jr. ::_Circuit Court Case #80-10415(20)
torney D/A: November 5, 1980
The intersection of S.W.
1st Street & S.W. 15th
Avenue
Plaintiffs, Caridad Viera & Fred Viera (her husband) filed
a claim against the City of Miami through their attorney
Jeffrey Allen Tew, of Tew, Spittler, Berger & Bluestein,
as a consequence of personal injuries received by Caridad
Viera in an automobile accident. An additional derivative
claim was brought on behalf of Fred Viera.
The accident occurred on November 5, 1980 at the inter-
section of S.W. 1st Street & S.W. 15th Avenue at approx-
imately 7:15 P.M. The ownership and operation of a City
of Miami Police vehicle was involved and responsibility
rests with the City of Miami.
Caridad Viera was driving her vehicle east on S. W. 1st
Street when she was hit on the driver's side by the City of
Miami police vehicle and spun approximately three times.
The City of Miami police vehicle was proceeding, in response
to a call, but without emergency lights or siren, south, the
wrong way down S. W. 15th Avenue which is one-way northbound.
The City police vehicle failed to yield the right-of-way to
Mrs. Viera who was on a through street. Liability rests
totally on the City of Miami vehicle.
Caridad Viera was 23 years old at the time of this accident.
She had been married about seven (7) years and had three (3)
children, ages 3, 4, and 5. She was employed at Astrup Com-
pany doing office work for two (2) months prior to this
accident and was making approximately $150.00 per week.
From the scene of the accident, she was taken to the Mercy
Hospital Emergency #oom where she was x-rayed and kept over-
night due to head injuries suffered.
Unable to return to work and still suffering two weeks later,
Caridad Viera sought treatment from conservative Orthopedic
Surgeon, Dr. Kenneth R. Hodar. Dr. Hodar diagnosed neck and
back injuries and treated her through August of 1981. Due
82_6SJ. .
The Honorable Members of
the City Commission
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to her persistent back complaints with complaints of pain
radiating into her right buttocks and positive straight leg
raising tests (tests for sciatic nerve root injury), Dr.
Hodar performed a CAT scan on her lower back. He discovered
a mild bulge of the disc in the low back but no conclusive
signs of a herniated disc. Dr. Hodar referred Caridad Viera
to Neuro-surgeon Jaime G. Wancier on May 21, 1981. Dr.
Wancier also failed to find any definitive neurological
clinical signs of injury. Dr. Wancier recommended further
conservative orthopedic treatment but no surgical neurolo-
gical testing.
Dr. Hodar continued to treat Caridad Viera until August 24,
1981 when he discharged her with the final diagnosis of chronic
lumbar radiculitis and assigned her a residual permanent dis-
ability of 5% to the body as a whole.
The City of Miami had Caridad Viera examined by Neurosurgeon
Irwin Perlmutter on December 8, 1981 and Orthopedic Surgeon
Ledford Gregory on December 15, 1981. Dr. Perlmutter again
ruled out any clinical signs of neurological injury. Dr.
Gregory found no residual permanent muscular skeletal impair-
ment but attributed at least some of Caridad Viera's problems
to a non -organic source. He recommended further exercise to
improve her condition.
Due to persistent headaches and feelings of depression,
Caridad Viera had begun treatment with Dr. Michael Gilbert
in December of 1980 after the accident. Dr. Gilbert is
both a Neurologist and Psychiatrist. Dr. Gilbert diagnosed
a post concussion syndrome and a depressive neurosis from
the accident. He treated the post concussion syndrome with
carbon dioxide treatments. He saw Caridad Viera twice a
month in thirty minute therapy sessions for the depressive
neurosis. In November of 1981, Dr. Gilbert assigned Caridad
Viera a 15% permanent partial disability due to her psychiatric
condition. She has continued to treat with him, although she
has stated, as has hbr husband, that there has been no change
in her psychiatric condition from the time of the accident.
The City of Miami had Caridad Viera examined by Psychiatrist,
Dr. Charles Mutter. Dr. Mutter disagreed with Dr. Gilbert's
The Honorable Members of -3-
the City Commission
course of treatment for Mrs. Viera but did reach the same
diagnosis of a nervous, traumatic depressive condition.
Dr. Mutter recommended further psychiatric treatment. At
a minimum, he felt that she would need at least one year of
therapy with sessions two times a week for two to four weeks
and then once a week thereafter. Dr. Mutter indicated that
therapeutic hypnosis could also be utilized to shorten treat -
went time. At the cost of $60.00 per hour, Dr. Mutter esti-
mates that this treatment would cost a minimum of $2,400.00.
Therapeutic hypnosis would increase the cost. Dr. Mutter felt
that there was a good possibility that Caridad Viera would not
be left with a permanent psychiatric injury if she received
proper treatment.
Caridad Viera's medical bills rendered by her treating doctors
totalled approximately $4,530.00 as of January of 1982. As
mentioned earlier, she has continued to see Dr. Gilbert.
Caridad Viera did not return to work after the accident.
For the first six months or so, Dr. Hodar advised against
this. She has failed to return to work due to her psychiatric
problems. The economic value of her services was analyzed
by H. T. Shulenberger, Esq., who has also qualified as an ex-
pert economist -statistician in Florida and Florida Courts.
Mr. Shulenberger based his predictions upon Caridad Viera's
projected life expectancy and expected additional years of
work together with an earning capacity starting at $7,500.00
per year ($150.00 times 50 weeks) which she could have rea-
sonably expected to earn at the time of the accident, adjust-
ed for inflation and numerous other economic indicators. He
predicted that Caridad Viera's economic services in a job
situation would be worth $376,171.00 reduced to present day
value. Her economic services as a housewife and mother as
opposed to an employment situation would be worth $387,193.00
reduced to present day value. To actually predict her loss,
a percentage of permanent partial disability would have to be
determined and applied to these figures. This economist -
statistician also indicated he could project her loss in a
combination situation of employment and household duties.
Based upon these figures, Plaintiffs' attorney indicated
that $52,500.00 of their demand was for lost past and future
services in wages.
82-655. .
The Honorable Members of -4-
the City Commission
All medical expenses, as well as employment history at the
time of this accident have been verified as to correctness.
Plaintiff's original total demand was for $100,000.00,
$50,000.00 for Caridad Viera and $50,000.00 for Fred Viera, _
' the limits available under Section 768.28, Florida Statutes
(1979). This was later reduced to $45,000.00. After ex-
tensive discussions and negotiations, the matter can now
be settled for $30,000.00.
This claim has been investigated by the City Attorney's
office in accordance with Ordinance No. 8417, which creates
the City of Miami's Self Insurance Program and the said
office recommends that the City of Miami pay $30,000.00
in settlement of this claim.
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