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HomeMy WebLinkAbout1994-225 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RESOLUTION NO. 94-225 RESOLUTION OF THE MAYOR AND COMMON COUNCIL OF THE CITY OF SAN BERNARDINO APPROVING A CERTAIN MUTUAL RELEASE AND SETTLEMENT AGREEMENT WITH OWNERS OF AND INTEREST HOLDERS IN UNDEVELOPED PARCELS WITHIN COMMUNITY FACILITIES DISTRICT NO. 995 WHEREAS, on June 18, 1990, the City of San Bernardino ("City") created Community Facilities 995 District No. ("District") pursuant to the Mello-Roos Community Facilities Act of 1982, codified at General Code Section 53311 et. seo. ("Act"); and WHEREAS, pursuant to the Act, in December, 1990, the City issued $7,325,000 Special Tax Limited Obligation Bonds, which are secured by the special taxes authorized to be levied against all parcels within the District; and WHEREAS, certain sums of special taxes duly levied pursuant to the Act against certain undeveloped parcels within the District subsequently became delinquent and remain unpaid; and WHEREAS, on January 14, 1994 and January 24, 1994, four (4) actions for judicial foreclosure of special tax liens were commenced in the San Bernardino Superior Court on behalf of the City against San Bernardino S.B. Five, Limited Partnership, Lakeview Seven Limited Development One Forty Company, Partnership, American National (sic) Bank, Donald E. Davis, Ruth Newbury, Irving M. Feldkamp III, Orange Coast Title Company, Ken -1- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 94-225 A. Kazarian, James C. Bice, Brimar Industries, Inc., and Does 1- 100, bearing Case Nos. SCV09593, SCV09594, SBCI09793 and SCV09790; and WHEREAS, pursuant to Section 53356.1 of the Act, the City has ratified the judicial foreclosure actions filed on January 14, 1994 and January 24, 1994 bearing San Bernardino Superior Court Case Nos. SCV09593, SCV09594, SBCI09793 and SCV09790, and has authorized the filing of an action for judicial foreclosure of the delinquent special tax liens associated with the undeveloped parcels owned by California Properties Fund within the District; and WHEREAS, the parties to the above referenced actions for judicial foreclosure now desire to resolve their differences and to avoid the expense and inconvenience of any future litigation. NOW, THEREFORE, THE MAYOR AND COMMON COUNCIL OF THE CITY OF SAN BERNARDINO, CALIFORNIA, DO HEREBY FIND, RESOLVE, DETERMINE AND ORDER AS FOLLOWS: Section 1. The Mayor and Common Council hereby approve the Mutual Release and Settlement Agreement with the owners of, and interest holders in undeveloped parcels within the District in the form attached hereto as Exhibit "A" and incorporated herein by this reference. III -2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 94~225 Section 2. The authorized and directed to Mayor of the City is hereby execute the Mutual Release and Settlement Agreement on behalf of the City with any such changes as may be approved by the Mayor and Counsel for the City. III III III III III III III III III III III III III III III III III III I I I III III III III III -3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 94-225 RESOLUTION OF THE MAYOR AND COMMON COUNCIL OF THE CITY OF SAN BERNARDINO APPROVING A CERTAIN MUTUAL RELEASE AND SETTLEMENT AGREEMENT WITH OWNERS OF AND INTEREST HOLDERS IN UNDEVELOPED PARCELS WITHIN COMMUNITY FACILITIES DISTRICT NO. 995 Section 3. This Resolution shall become effective immediately upon its adoption. I HEREBY CERTIFY that the foregoing Resolution was duly adopted by the Mayor and Common Council of the City of rcg1l1;'lr meeting San Bernardino at a 1st August day of thereof, held on the 1994, by the following vote, to wit: 4th AYES: Council Members Negrete, Curlin, Hernandez, Oberhelman, Devlin, Pope-Ludlam and Miller NAYS: ABSENT: ~" ('t/i "L ~~7c:. ity Clerk The foregoing resolution is hereby approved this day of August , 1994. ~ )?itP~ Mayor of the City of San Bernardino Approved as to form and legal content: JAMES F. PENMAN City Attorney ;') By/M~L&<~ -' -4- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 94-225 STATE OF CALIFORNIA COUNTY OF On before me, (here insert name and title of the officer), personally appeared , personally known to me (or proved to me on the basis of satisfactory evidence) to be the person(s) whose name (s) islare subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity (ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. Signature (Seal) , \~-,,~,:?''':':',> U'___\ <-'," , EXHIBI'r "A" MUTUAL RELEASE AND SETTLEMENT AGREEMENT This Mutual Release and Settlement Agreement ("Agreement") is entered into this day of August, 1994, by and between the CITY OF SAN BERNARDINO ("City") and James C. Bice, Thomas W. Coenen and Betsy A. Coenen, One Fifty Limited Partnership, California Properties Fund, Brimar Industries, Inc., Security Trust Company, Julian A. Pearson, National Bank of Long Beach, Orange Coast Title Company, Donald E. Davis, Ruth Newburg, Irving M. Feldkamp III, Ken A. Kazarian, Lakeview Development Company, One Forty-Seven Limited Partnership, American International Bank, and San Bernardino Sb Five Limited (jointly referred to herein as "Developers"). The City and Developers are collectively referred to as the "Parties". 1. RECITALS 1.1. Each of the Developers own or have an interest in unimproved property located within the City's Mello-Roos District No. 995, which properties and the Developers owning or having an interest in them, are more fully described in Exhibit "A" attached hereto. On or about January 14, 1994, and January 24, 1994, the City commenced four (4) actions for judicial foreclosure of delinquent special taxes in the Superior Court of the State of California for the County of San Bernardino, against certain named defendants therein, including Developers, bearing Case Nos. SCV09593, SCV09594, SBCI09793, and SCV09790. A dispute concerning delinquent special taxes also exists between the City and California Properties Fund. Case Nos. SCV09593, SCV09594, SBCI09793, and SCV09790 and the dispute with California Properties Fund shall collectively be referred to as the "Actions". 1.2. The Parties now desire to resolve their differences and to avoid the expense and inconvenience of any future litigation, including without limitation, litigation of the Actions. 1.3. Except as expressly reserved herein, it is the intention of the Parties hereto to settle and dispose of, fully and completely, any and all claims, demands and causes of action relating to the Actions, or to any dealings between the City and the Developers prior to the effective date of this Agreement and relating to the subject matter hereof. 1. 4. In promises herein hereafter. consideration of the covenants, contained, the Parties agree conditions and as set forth - 1 - 94 225 2. SETTLEMENT TERMS AND CONDITIONS 2.1. Each of the Developers shall pay, with respect to that Developer's property, delinquent fiscal year 1991- 92, 1992 - 93, and 1993-94 special taxes in five (5) equal payments of principal and interest amortized for five (5) years, with the first payment commencing one (1) year after the effective date of this Agreement and subsequent payments to be paid annually thereafter. The principal amount of the debt shall be equal to delinquent special taxes, interest, penalties, collection costs, legal fees associated with the Actions, and consultant fees which have been paid or incurred by the City as of the date of this Agreement, related to the 1991-92, 1992-93, and 1993-94 delinquent special taxes. Delinquent tax amounts shall bear interest at the rate of eight percent (8%) per annum, commencing upon the date of the issuance of the Refunding Bonds, until paid. The five (5) equal payments made under this Section and prepayments, if any, shall be applied to mandatory redemption of the Refunding Bonds, after any deficiencies under Section 2.9 for the payment of debt service on the Refunding Bonds have been paid. Late payments shall bear interest at the rate of ten percent (10%) per annum until paid, and shall also be applied to cause a mandatory redemption of the Refunding Bonds. Developers shall be authorized to sell their properties during such time as the 1991-92, 1992-93, and 1993-94 delinquencies associated with the properties remain in existence, provided that the City's security in the properties is not diminished. Upon each and every sale, Developers shall either substitute collateral as determined to be adequate by the City, or agree to pay the release price per lot sale as established by the City. 2.2. In the event any payment due under this Agreement is not received within ten (10) days of its due date, City may at its option cause entry of the Judgments as set forth in Sections 2.10 and 5.1 below against the defaulting Developers, bring suit under this Agreement or proceed with any and all other remedies available to it at law or in equity. 2.3. Each of the Developers shall also pay, with respect to that Developer's property, the Verdemont Infrastructure Fees at such time as development occurs, at the rate applicable in December, 1990, or such lesser amount as may then be imposed. 2.4. Each of the Developers shall also pay, with respect to that Developer's Property, school facilities mitigation fees at such time as development occurs, at the rate then in effect as determined by the San Bernardino City Unified School District ("School District"). 2.5. In addition to the Verdemont Infrastructure Fees to be paid pursuant to Section 2.3 above, each of the Developers shall also pay to the City that Developer's proportionate amount of school facilities mitigation fees representing houses previously - 2 - 94 225 built for which no school facilities mitigation fees have been paid (i.e., 163 houses x $3,502 per house = $570,826), unless the School District otherwise agrees in. writing to waive such school facilities mitigation fees. 2.6. Developers shall agree that no additional Mello-Roos bonds with respect to their properties will be issued until the special tax formula is amended to provide that any special tax increases which are attributable to such additional bonds will not cause an increase in the then levied special tax amount to the 163 homeowners as the principal amount of the Refunding Bonds is reduced by mandatory redemptions from Developer payments of fiscal year 1992-93 and 1993-94 delinquencies, plus interest pursuant to Section 2.1 above. 2.7. Each of the Developers shall indemnify, defend and hold harmless the City, its elected officials, staff, employees and consultants, other than as provided in Section 2.8 below, from any financial liability or loss, including attorneys' fees and court costs as a result of any City actions with respect to the issuance of the Bonds, the levy of the special tax, the formation of Mello- Roos District No. 995 and the implementation thereof, the interpretation of the Bond documents, and from any cross-complaints or other actions as may be filed as a result of the Developers' lawsuits pursuant to Section 2.8 below. 2.8. Developers may file suit in an effort to obtain any financial relief from Orrick, Herrington & Sutcliff, David Taussig & Associates, prudential-Bache Capital Funding, Lillick & McHose, and/or Charles R. Wilson & Associates, Inc. No relief shall be sought or obtained against the City in any such action. 2.9. Refunding Bonds shall be issued, the proceeds of which, together with unexpended Verdemont Infrastructure Fees and school facilities mitigation fees, will be sufficient to pay the September 1, 1994 principal and interest payment on the 1990 Bonds and will establish a defeasance escrow fund that will satisfy and discharge the claims of the owners of the 1990 Bonds under the Fiscal Agent Agreement dated November 1, 1990. The Refunding Bonds debt service shall be provided from the 163 single family houses (i.e., 163 houses x $1,300 per house = 211,900 per year). Mandatory redemptions of the Refunding Bonds shall be made from payments by the Developers as provided in Section 2.1 above. Vacant land shall remain contingently liable for the Refunding Bond debt service and administrative costs, but it is the intent that the vacant land should pay only a nominal special tax, if any. 2.10. Concurrent with the execution of this Agreement, Developers shall provide counsel for the City with executed Stipulations For Entry Of Judgment ("Stipulations"), copies of which are attached hereto as Exhibit "B" and are incorporated herein by this reference. Counsel for the City may cause the - 3 - 94 225 Stipulations to be filed with the San Bernardino Superior Court immediately thereafter. In accordance with the Stipulations, the City may cause entry of Judgments, copies of which are attached hereto as Exhibit "cn and are incorporated herein by this reference, against Developers in the event any payment due under this Agreement is not received within ten (10) days of its due date, or any condition set forth under this Agreement is not satisfied. The Stipulations further provide that upon payment in full of the sums due under this Agreement and upon occurrence of the conditions set forth under this Agreement, the City shall cause dismissal(s) to be filed in the applicable Action(s). Notwithstanding Code of Civil Procedure Section 583.310 and any applicable statute of limitations, the City shall have the right to cause entry of Judgments in the Actions without penalty should thi:3 Agreement not be consummated. The parties expressly agree to waive Code of Civil Procedure Section 583.310 and any applicable statute of limitations to the extent necessary to allow the City to cause entry of Judgments in the Actions in the event the settlement contemplated within this Agreement is not consummated. 2.11. Developers shall bear their own attorneys' fees and costs incurred in connection with the Actions. 2.12. This Agreement has been duly ratified, accepted and consented to by the City, through the action of its City Council. The representatives signing this Agreement on behalf of the City expressly represent that he or they do so with the full authority and consent of the City. 3 . RELEASE 3.1. Upon the occurrence of the events and conditions set forth in Sections 2.1 through 2.12, inclusive, the City, on its own behalf and on behalf of its agents, assignees, transferees, representatives and successors in interest, fully and generally release and forever discharge Developers and their past and present representatives, predecessors, successors and assigns, insurers, attorneys, employees, officers, trustees, directors, agents, consultants, servants, partners, limited partners, other representatives and their related entities, and all persons acting by, through and/or in concert with any of them, from and against any and all claims, any and all known and unknown liabilities, demands, damages, expenses, costs, attorneys' fees, obligations, and causes of action of any kind whatsoever related to or arising out of the Actions, or which could have been alleged in the Actions. 3.2. Upon the occurrence of the events and conditions set forth in Sections 2.1 through 2.12 inclusive, Developers on their own behalf and on behalf of their agents, assignees, transferees, representatives and successors in interest, fully and generally release and forever discharge the City and its past or present - 4 - 94 225 representatives, predecessors, successors, assigns, insurers, attorneys, employees, officers, trustees, directors, agents, consultants, servants, partners, limited partners, other representatives and their related entities, and all persons acting by, through andlor in concert with any of them, from and against any and all claims, and any and all known and unknown liabilities, demands, damages, expenses, costs, attorneys' fees, obligations, and causes of action of any kind whatsoever arising out of the Actions, or which could have been alleged in the Actions. 3.3. Each Party acknowledges that the release set forth herein by the Parties hereto is a full and complete general release of the claims for damages, debts, liabilities, demands, obligations, costs, expenses, compensation, actions, and causes of action, which are described herein, and is intended to encompass all known and unknown, foreseen and unforeseen, claims which Developers and the City may have against one another. Accordingly, each Party hereto does hereby expressly waive and relinquish any and all rights and benefits which each may otherwise have against the other pursuant to Section 1542 of the California Civil Code which provides that: A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM, MUST HAVE MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR. 3.4. Each Party acknowledges that he, she or it may hereafter discover facts different from, or in addition to, those which he, she or it now knows or believe to be true, with respect to the Actions or other matters which are the subject of this Agreement, and the Parties each hereby expressly agree to assume the risk of the possible discovery of additional or different facts, and agree that this Agreement shall be and remain effective in all respects regardless of such additional or different facts. 3.5. The Parties warrant that, except as provided herein, each has the power to settle and release fully and completely all claims, causes of action, demands, charges, and liabilities against the other, arising out of or relating to the Actions, and that each person is duly authorized and empowered to sign this Agreement. 4. MISCELLANEOUS PROVISIONS. 4.1. This Agreement shall executors, administrators, successors assignees of each Party herein. It benefit of each Party's respective servants, directors, shareholders, bind the respective heirs, in interest, transferees, and shall bind and inure to the past or present employees, agents, insurers, partners, - 5 - 94 225 limited partners, attorneys, successors in interest, representatives, related entities and assigns. other 4.2. This Agreement contains the entire understanding of the Parties with respect to the subject matter hereof, and no modification or waiver of any of the provisions hereof shall be valid unless and until it is put into writing and executed by the Party(s) to be bound thereby. 4.3. This Agreement shall be governed in accordance with the Laws of the State of California. Any action brought to enforce or interpret this Agreement, or any part thereof, shall be brought in the State of California, in the County of San Bernardino. 4.4. Whenever possible, each provision of the Agreement shall be interpreted in such a manner as to be valid under applicable California law; but, if any provision of this Agreement shall be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected thereby and any such illegal or invalid part, term or provision shall not be deemed to be part of this Agreement. 4.5. The Parties each represent that they have investigated the facts they deem necessary, have consulted with their respective legal counsel regarding said facts and the attendant risks of settlement pursuant to this Agreement, and are not relying upon any representations or acknowledgement, whether oral or in writing, of any other Party hereto except as contained herein. 4.6. The Parties hereto agree to perform such acts and to prepare, execute, file and record any documents or stipulations reasonably required to perform the covenants and satisfy the conditions herein contained. 4.7. This Agreement is the compromise of disputed claims and upon the performance of the covenants contained herein by Developers, fully and finally settles all claims between Developers and the City stemming from any and all dealings, contracts or transactions between them, from the beginning of time, related to the subject matter hereof, and is intended to buy peace and to prevent any further involvements and disputes. Neither the payment of any consideration hereunder or anything contained in this Agreement shall be interpreted or construed to be an admission on the part of, or to the prejudice of any Party to this Agreement. Except for the obligations created by this document and the Exhibits attached hereto which are incorporated by reference herein, each Party hereto expressly denies any and all liability associated with or related to the Actions and claims described therein. - 6 - 94 '}nr: ;.. ~.. :.:> , 4.8. Each Party hereto acknowledges and represents that no promise, representation or inducement not herein expressed has been made in connection with this Agreement. 4.9. Each Party hereto certifies that he, she or it has read all of this Agreement and fully understands all of the same. 4.10. This Agreement shall be construed without regard to who drafted same and shall be construed as though all Parties hereto participated equally in the drafting of this Agreement. 4.11. This Agreement consists of (___) pages, including Exhibits "A", "B", and "C" and may be executed in counterparts, each of which shall be deemed an original, and which together shall constitute one and the same instrument. 4.12. This Agreement contains the entire agreement between the Parties hereto and the terms of this Agreement are contractual and not a mere recital. 4 .13. Notwithstanding the provisions of Section 5.1, below, in the event any party breaches a material provision of this Agreement, it may be specifically enforced or rescinded, at the election of the non-breaching party, in addition to other equitable and legal remedies. 4.14. In the event that any Party hereto shall institute any action or proceeding to enforce or interpret any of the rights granted or released hereunder, the prevailing Party in such action or proceeding shall be entitled to recover all of his, hers, its or their costs and expenses incurred in the action or proceeding, including, but not limited to, reasonable attorneys' fees and court costs. 4.15. The effective date of the Agreement shall be deemed to be August __, 1994. 5. JUDICIAL PROCEEDINGS 5.1. The Actions are stayed as of August ,1994. The Parties agree that the trial date and law and motion dates, if any, shall be vacated, subject to being reset upon noticed motion brought by any party, accompanied by appropriate declaration (s) reciting failure of a condition of the Agreement. The Parties hereby further agree that the time within which an action must be brought to trial, pursuant to code of civil Procedure Section 583.310 (five year limitation), shall be hereby tolled by the express agreement of the Parties, pursuant to Code of Civil ,Procedure Section 583.330, and that the present date to bring the matter to trial within the five (5) year period is extended by all Parties for the period of time that the settlement terms, pursuant to this Agreement, are pending but not "consummated" (i.e., all - 7 - 94 225 conditions satisfied and the sums paid as agreed). All applicable limitations regarding discovery are tolled, pending further order of the Court. DATED: August DATED: August DATED: August DATED: August DATED: August DATED: August DATED: August DATED: August DATED: August DATED: August , 1994 CITY OF SAN BERNARDINO By: , 1994 James C. Bice , 1994 Thomas W. Coenen , 1994 Betsy A. Coenen , 1994 ONE FIFTY LIMITED PARTNERSHIP By: , 1994 CALIFORNIA PROPERTIES FUND By: , 1994 BRlMAR INDUSTRIES, INC. By: , 1994 SECURITY TRUST COMPANY , 1994 By: SAN BERNARDINO Sb FIVE LIMITED By: , 1994 Julian A. Pearson - 8 - l ~4 ??5 DATED: August , 1994 NATIONAL BANK OF LONG BEACH By: DATED: August , 1994 ORANGE COAST TITLE COMPANY By: DATED: August , 1994 Donald E. Davis DATED: August 1994 Ruth Newburg DATED: August , 1994 Irving M. Feldkamp III DATED: August , 1994 Ken A. Kazarian DATED: August , 1994 LAKEVIEW DEVELOPMENT COMPANY By: DATED: August 1994 ONE FORTY-SEVEN LIMITED PARTNERSHIP By: DATED: August 1994 AMERICAN INTERNATIONAL BANK By: - 9 - ~4 .,<)~ fit! "...~ fll1 ')t)l': 94 225 APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 SABO & GREEN, A Professional Corporation By: Timothy J. Sabo Attorneys for City of San Bernardino APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for James C. Bice APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Thomas W. Coenen and Betsy A. Coenen APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for California Properties Fund APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Brimar Industries, Inc. - 10 - 94 225 APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Security Trust Company APPROVED AS TO FORM AND CONTENT: DATED: August __, 1994 By: Attorneys for San Bernardino Sb Five Limited APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Julian A. Pearson APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for National Bank of Long Beach APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Orange Coast Title Company - 11 - 94 ??5 APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Donald E. Davis APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Ruth Newburg APPROVED AS TO FORM AND CONTENT: DATED: August ,1.994 By: Attorneys for Irving M. Feldkamp III APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Ken A. Kazarian APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for Lakeview Development Company APPROVED AS TO FORM AND CONTENT: DATED: August ,1994 By: Attorneys for One Forty-Seven Limited Partnership - 12 - 911 . 94 '>,,!!: 0')5 .... APPROVED AS TO FORM AND CONTENT: DATED: August __, 1994 By: Attorneys for American International Bank SBEO/0121/DOC/15 7/26/94 12:25 - 13 -