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HomeMy WebLinkAboutMemorandumCITY OF MIAMI OFFICE OF THE CITY ATTORNEY MEMORANDUM TO: Honorable Mayor and Members of the City Commission FROM: Victoria Mendez /! DATE: November 17, 2022 RE: Proposed Resolution for City Commission Meeting- November 17, 2022 Settlement of Steven Miro vs. City of Miami, pending in the Eleventh Judicial Circuit in Miami -Dade County, Case Number 19-30366-CA-01 File No.: 12942 The City is currently engaged in litigation with former City employee Steven Miro ("Miro"). Miro claims that the City terminated his employment in 2018 due to his involvement in an investigation by the State Attorney's Office. Miro filed a one -count complaint in the Eleventh Judicial Circuit in Miami -Dade County alleging that the City violated Section 112.3187 of the Florida Statutes, otherwise known as Florida's Public Whistleblower Act. As part of the litigation, Miro is demanding all backpay from 2018 to present, reinstatement with all seniority and emoluments, attorney's fees, and costs. Miro's initial offer two years ago was more than three -hundred -thousand -dollars ($300,000.00). The City was able to negotiate the settlement of this matter for one -hundred -and - twenty -thousand -dollars ($120,000.00). This amount represents the costs of defense (i.e. atty fees, witness fees, court reporter fees, etc.) of this claim. This amount also constitutes a final and complete settlement and waiver of all claims against the City, its employees and agents. Lastly, it encompasses backpay, attorney's fees and costs and ensures the Plaintiff remains terminated. Since the initiation of this litigation, several witnesses have moved out of South Florida or have retired from the City of Miami. As a result, in addition to the uncertainty of litigation, there are companion costs associated with producing numerous witnesses for trial. Based on the foregoing, the City's Attorney's Office recommends passing the Resolution that approves a settlement of this claim. cc: Art Noriega, City Manager Miriam M. Santana, Agenda Coordinator Enclosure(s) Attachment(s) 12942 Commissioner Carollo-Form 8B Voting Conflict City of Miami Legislation Resolution Enactment Number: R-22-0465 City Hall 3500 Pan American Drive Miami, FL 33133 www.miamigov.com File Number: 12942 Final Action Date:11/17/2022 A RESOLUTION OF THE MIAMI CITY COMMISSION AUTHORIZING THE DIRECTOR OF FINANCE TO PAY STEVEN MIRO ONE -HUNDRED -AND -TWENTY -THOUSAND - DOLLARS ($120,000.00) IN FULL AND COMPLETE SETTLEMENT OF ANY AND ALL CLAIMS AND DEMANDS BY HIM, INCLUDING ALL CLAIMS FOR ATTORNEYS' FEES AND COSTS, AGAINST THE CITY OF MIAMI, ITS OFFICERS, AGENTS, AND EMPLOYEES IN THE CASE OF STEVEN MIRO VS. CITY OF MIAMI, CASE NO. 19- 30366-CA-01, PENDING IN THE ELEVENTH JUDICIAL CIRCUIT IN MIAMI-DADE COUNTY, UPON THE EXECUTION OF A GENERAL RELEASE OF HIS CLAIMS AND DEMANDS, AND A DISMISSAL OF HIS CLAIMS AGAINST THE CITY OF MIAMI WITH PREJUDICE; ALLOCATING FUNDS FROM GENERAL LIABILITY ACCOUNT NO. 50001.301001.545013.0000.00000. WHEREAS, Steven Miro and the City of Miami ("City") are engaged in litigation in the Eleventh Judicial Circuit in Miami -Dade County, Case No. 19-30366-CA-01; and WHEREAS, the City Attorney's Office has investigated these claims and the lawsuit pursuant to Sections 18-221 through 18-232 of the Code of the City of Miami, Florida, as amended, and recommends that the claims of Steven Miro be settled for the lump sum of one - hundred -and -twenty -thousand -dollars ($120,000.00) including all claims for attorneys' fees and costs; NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE CITY OF MIAMI, FLORIDA: Section 1. The recitals and findings contained in the Preamble to this Resolution are adopted by reference and incorporated as if fully set forth in this Section. Section 2. The Director of Finance is authorized' to pay Steven Miro, without admission of liability, one -hundred -and -twenty -thousand -dollars ($120,000.00) in full and complete settlement of any and all claims and demands, including all claims for attorneys' fees and costs, against the City, its officers, agents, and employees in the case of Steven Miro vs. City of Miami, Case No. 19-30366-CA-01, pending in the Eleventh Judicial Circuit in Miami -Dade County, upon the execution of a general release of all his claims and demands and a dismissal of his claims against the City with prejudice. Section 3. Funds are allocated from General Liability Account No. 50001.301001.545013.0000.00000. Section 4. This Resolution shall become effective immediately upon its adoption. The herein authorization is further subject to compliance with all legal requirements that may be imposed, including but not limited to, those prescribed by applicable City Charter and City Code provisions. APPROVED AS TO FORM AND CORRECTNESS: