HomeMy WebLinkAboutR-82-0541� JL
RESOLUTION NO.
A RESOLUTION AUTHORIZING THE DIRECTOR
OF FINANCE TO PAY TO ANDRES FIALLO,
A MINOR, BY AND THROUGH HIS MOTHER
AND NATURAL GUARDIAN, MARTHA FIALLO,
AND MARTHA FIALLO, INDIVIDUALLY,
THE SUM OF EIGHTEEN THOUSAND DOLLARS
($18,000.00) PLUS UP TO THREE HUNDRED
DOLLARS ($300.00) IN TAXABLE COSTS,
WITHOUT THE ADMISSION OF LIABILITY,
IN FULL AND COMPLETE SETTLEMENT OF
ALL BODILY INJURY, PERSONAL INJURY,
PROTECTION LIENS, WORKMEN'S COMPEN-
SATION LIENS, CLAIMS AND DEMANDS
AGAINST THE CITY OF MIAMI AND UPON
EXECUTION OF THE RELEASE RELEASING
THE CITY FROM ALL CLAIMS AND DEMANDS.
WHEREAS, Andres Fiallo, a minor, by and through his
mother and natural guardian, Martha Fiallo, and Martha
Fiallo individually, through P. J. Carroll, Esq., of Carroll,
Halberg & Meyerson, P.A., their attorneys, filed a claim
against the City of Miami for alleged bodily injury, personal
injury, protection liens, Workmen's Compensation liens,
resulting from an accident involving a City owned vehicle on
April 16, 1978 on Northwest 1st Street in front of the
address of 737 Northwest 1st Street, 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 Eighteen Thousand Dollars ($18,000.00) and up
to Three Hundred Fifty Dollars ($350.00) in costs;
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 Andres Fiallo, by and through his mother and natural
guardian, Martha Fiallo, the sum of Eighteen Thousand Dollars
CITY COMMISS1011
MEETING ON
JUN 17 19M
94Mx �2-541
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I%k
($18,000.00) and up to Three Hundred Fifty Dollars ($350.00)
in costs, without the admission of liability, in full and
complete settlement of all bodily injury, personal injury,
protection liens, Workmen's Compensation liens, claims and
demands against the City of Miami, upon execution of the re-
lease releasing the City of Miami from bodily injury, per-
sonal injury, protection liens, Workmen's Compensation liens
and claims and demands.
PASSED AND ADOPTED this 17th day of June, 1982.
EST:/
ZRAL G. ONGIE
ITY CLERK
PREPARED AND APPROVED BY:
1 a J. o erts
Assistant City Attorney
Maurice A. Ferre
Maurice A. Ferre
Mayor
APPROVED AS TO�`®R T D CORRECTNESS:
G&orA F. nox, Jr.
CityJAttorney
82--541-.L.
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r
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CITY OF MIAMI, FLORIDA
INTER -OFFICE MEMORANDUM
TO
Honorable Members of
the City Commission
FROM
DATE
June 1, 1982
FILE
SUBJECT
Settlement of Andres Fiallo, etc.,
et al. v. The City of Miami,
Circuit Court Case No. 81-2492(12)
REFERENCES
Ge r F. Knox; Jr: D/A: April 16, 1978
City ttorney ENCLOSURES P/A: N.W. 1st Street in Front of
737 N.W. lst-19-trePt�y___-Miami
Plaintiffs, Andres Fiallo, a minor, by and through his
mother and natural guardian, Martha Fiallo, and Martha
Fiallo, individually, filed a claim against the City of
Miami through their attorney P. J. Carroll, Esq. of Carroll,
Halberg & Meyerson, P.A., for injuries sustained by Andres
Fiallo as the result of a pedestrian/motor vehicle accident.
The claim of Martha Fiallo is a derivative action brought
to recover Andres Fiallo's medical expenses.
The accident occurred on April 16, 1978 at approximately
6 P.M. in front of 737 Northwest 1st Street. Minor Plain-
tiff, Andres Fiallo, age 4 years, ran out into the street
in front of the City of Miami police patrol vehicle driven
by Officer Bette Majewski.
Eyewitnesses to the accident all agreed the Plaintiff ran
in front of the police officer's vehicle. None of the eye-
witnesses could state whether or not the police officer
was watching both sides of the street. Minor Plaintiff's
brother, age 7 at the time of the accident, and another
eyewitness in the street, stated that minor Plaintiff
was chasing his brother who had ran across the street
immediately prior to the accident. Officer Bette Majewski
had a misdemeanor vandalism suspect in the back of her vehicle.
According to that suspect, they were cruising the street
looking to the officer's right for a companion suspect.
The minor Plaintiff came from the officer's left.
Officer Bette Majewski is unavailable to testify at trial
as she suffers from a total temporary disability based
on psychological problems relating to her job. Her psychiatrist
has indicated that further involvement at this time would have
a detrimental effect on her mental condition.
82-w541`L.
1y
Honorable Members of
the City Commission
-2- June 1 , 1982
The City of Miami has a counterclaim against the mother
Martha Fiallo for contributions due to her failure to
supervise the minor Plaintiff. Although the City Attorney's
office believes that this is a good claim, Martha Fiallo is
currently unemployed, without insurance, and judgment proof.
Therefore, the City would not be able to actually recover
from her. In the meantime, it is felt that the City's
employee will be found at least minimally negligent and the
City would therefore be responsible to the Plaintiff Andres
Fiallo for the total of his damages. A finding of comparative
negligence as to the mother would not reduce the amount the
City would owe the minor.
Minor Plaintiff, Andres Fiallo, suffered a fractured right
leg and multiple abrasions. He was hospitalized from
April 16, 1978 through May 5, 1978. The first three (3)
days were spent in the Pediatric Intensive Care Unit at
Jackson Memorial Hospital. Subsequently, he was restricted
to bed and his leg was in traction and a cast.
After discharge from the hospital, Plaintiff continued to
wear a body cast extending from under his left armpit to
below his right knee for at least one month. Plaintiff was
put into a smaller cast for the next three (3) months.
In November of 1979, Plaintiff was examined by local con-
servative orthopedic Surgeon Claude Holmes. At that time,
mother of Andres Fiallo stated that Plaintiff was more
nervous since the accident and suffered from headaches.
Dr. Holmes upon examination found the left leg approxi-
mately 5/81' shorter than the injured right leg. Although
the doctor indicated that the minor Plaintiff has normal
function, he did assign a slight residual permanent
partial impairment due to the slight lengthening of the
right leg.
Minor Plaintiff, four (4) years after the accident, still
complains of weakness in the right leg which causes him
to fall frequently while playing. These falls are occasionally
severe enough to cause headaches lasting two to three hours
with aspirin and rest necessary to relieve them.
82-541'
rrj
Honorable Members of -3- June 1 , 1982
the City Commission
In addition to treatment by the doctors at Jackson Memorial
Hospital, and an examination by Dr. Holmes, Plaintiff was
also seen by Illinois Welfare Physicians who removed his
cast while he was in Chicago during the Summer of 1978.
No bills were received from these welfare doctors.
Plaintiff's total medicals known from this accident are
$3,804.06.
All of the medical expenses and other damages have been
verified as to correctness. The original demand presented
on behalf of minor Plaintiff was for the $50,000.00 limit
established under Section 768.28, Florida Statutes (1975).
This was later reduced to $20,000.00 plus medicals as
a final figure. After extensive discussions and nego-
tiations, the matter can now be settled $18,000.00,
plus approximately $350.00 in taxable costs.
This claim has been investigated by the City Attorney's
Office and in accordance with Ordinance 8417, which
creates the City of Miami's Self -Insurance Program,
the said Office recommends that the City of Miami make
an Offer of Judgment to settle this claim in the amount
$18,000.00 and up to $350.00 in costs.
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