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Home My WebLink About1986-528 iC"~'" 1"'-' ''''''" ~" '7:.. <;;,:';". .':~!. .,'i;;:',.~:,;._~V'i"j,., . . ;i~'~",',..,. ".' .';'<.~'it; 1 RESOLUTION NO. 86-528 2 RESOLUTION OF THE CITY OF SAN BERNARDINO AUTHORIZING THE EXECUTION OF AN AGREEMENT FOR PAYMENT OF JUDGMENT IN THE WALSH v. 3 CITY OF SAN BERNARDINO LAWSUIT. 4 BE IT RESOLVED BY THE MAYOR AND COMMON COUNCIL OF THE CITY OF 5 SAN BERNARDINO AS FOLLOWS: 6 SECTION 1. The Mayor of the City of San Bernardino is hereby 7 . authorized and directed to execute on behalf of said City an 8 Agreement for payment of Judgment in the Walsh v. City of San 9 Bernardino lawsuit, a copy of which is attached hereto, marked 10 Exhibit "A" and incorporated herein by reference as fully as 11 though set forth at length. Said execution by the Mayor shall be 12 deferred until all plaintiffs have executed the agreement. 13 I HEREBY CERTIFY that the foregoing resolution was duly 14 adopted by the Mayor and Common Council of the City of San 15 Bernardino at an adiourned reqular meeting thereof, held on 16 the 22nd day of 17 to wit: December , 1986, by the following vote, 18 19 20 21 22 23 24 Council Members Reill AYES: Marks Frazier Strickler. NAYS: None Council Members Estrada Hernandez ABSENT: uiel The foregoing resolution is Clty Clerk approved this ~~~~ day 25. of 26 December , 1986. 27 Approved as to form: 28 ~nP~ City Attorney ..... " -, ~ ; 1....07.000 "'v.IO/11 ~ . ) .. ;' ..J'~$;:!J . MINUTES OF THE BOARD OF 5m>ERVISORS tV '.fi'. '\~ l~j;;:i;,\ . fro \ <Ii". .\ FCD-Cyn~=~F SAN BERNARDINO COUNTY, CAUFORNIA ,~) ~ '/4// ; .S.\ ' (') r' ' ~.,? ---j\ FCD'eounZDne 21 Gen(4D91); December 22, 1986 << ; .. dl ~. ~- ; ~ Inc. Cities-~ ~.; if AgrTransp'S-Ham:>6 140 s e 'lie.; <(:c' -t:; ee. 6-11 ~:i~'~'~"('--r,,,,!,-<'<G'Y MICHAEL G. WALKER, Director ALAN K. MARKS ~.../ Transportation/Flood Control/Airports County Counsel ,. Filed: FROM: SUBJECT: FLOOD CONTROL DISTRICT ZONE 2 - AGREEMENT WITH CITY OF SAN BERNARDINO, LAW FIRM OF BREKHUS AND WILLIAMS REPRESENTING HAMPSHIRE AVENUE PLAINTIFFS, AND SAN BERNARDINO COUNTY FLOOD CONTROL DISTRICT. RECOMMENDATION: Approve Agreement with City of San Bernardino, law firm of Brekhus and Williams and Hampshire Avenue plaintiffs, and San Bernardino County Flood Control District regarding payment of Superior Court judgment of Walsh, et a1 vs. State of California, action No. 199364 and George et a1 vs. State of California, action No. 209924 and authorize Chairman to execute Agreement. BACKGROUND INFORMATION: In 1980 the plaintiffs filed with the Superior Court of San Bernardino County, Walsh, et a1 vs. State of California, et a1, action No. 199364 and George et a1 vs. State of California et a1, action No. 209924. On June 24, 1986, a judgment was entered in favor of the plaintiffs in the amount of $4,089,629.46. Staff was directed by the Board of Supervisors to negotiate with City of San Bernardino and plaintiffs an Agreement for payment of the judgment. The District's portion of the judgment will be paid in three installments; the first ($500,000) on or before December 31, 1986, the second ($500,000) on or before June 30, 1987, and the last ($400,000, plus interest) no earlier than January 2, 1988, and no later than June 30, 1988. REASON FOR RECOMMENDATION: Payment and satisfaction of this judgment is pursuant to terms of the Agreement. REVIEW BY OTHERS: The Agreement has been reviewed by the County Counsel. FINANCIAL DATA: The payment of the judgement was not budgeted, however, funds are available by deferring construction projects in the current year and fiscal year 87/88. The District's share of the judgment is $1,400,000 plus interest. PRESENTER: Michael G. Walker c: Co. C'rn-nAP.l-FA RnninQnt1 w/,q~~~t: City of San Bernardino w/agree. c/o ~. Counsel Brekhus & Williams, Attome w/agree. c/o Co. Counsel Auditor w/agreE!lllmt Flood Ca1trol w/ agreE!lllmt EPWA File w/ agreE!lllmt Action of the Board of Supervisors AGREEMENT NQ.; 85,.1140 APPROVED eOARO Of SUPERVISORS COUN1YOF SAN BERNARDINO MOTION ~__ Secmd .~tion _ X 1 234 ~~~.~ DATED' D 1986 XX . ~M Absent 5 ~ . Settlement A reement - 19BO San Bernardino County Flood Contr rm Oama e CONTRACT NUMBER istrict 86-1140 Flood Control District Contract Representative o Renewable XX Terminates 3320 Amount of Contract Mike Walker Budget Unit No. Sub-Object No. 010 FOOB36 $1,400 001.00 SAN BERNARDINO COUNTY FLOOD CONTROL DISTRICT CONTRACT TRANSMITTAL Check One: OExpenditure S.S.A. o Revenue If contract has more than one payment or receipt, complete the following. Number of payments: Estimated amount of each: See below $ See below or Federal Employer 10 # Contractor~: CITY OF SAN BERNARDINO: and BREKHUS & WILLIAMS. Attornevs at Law Contractor's Representative: Address: Phone Nature of Contract: (Briefly describe the general terms of the contract.) To provide for payment of the Judgment in Walsh, et al. v. State of California, et al. and Georqe, et al. v. State of California, et al. 1) Funds to be deposited with the San Bernardino County Superior Court through an action in interpleader on behalf of plaintiffs James and Shirley Lynas: City of San Bernardino - $121,029.00 (plus interest) Flood Control District - $ 60,515.00 (plus interest) 2) Payments to be made to remaining plaintiffs through their attorney, Brekhus & Williams: Flood Control District City of San Bernardino On or before 12/31/86 On or before 6/30/87 Between 1/2/88 and 6/30/88 $439,486.00 $500,000.00 $400,000.00 (plus interest) $1,878.970.00 $ 701,321.34 (plus interest I MARTHA M. SCUDDER. Clerk 01 the Board 01 Supervisors 01 the' .CoUnty or.SanBernardi~o, State 01 California,hereby certllythe foregoing instrument to be a lull. true' and correct copy 01 the original now on file in my 011 ice. Dated: . ::"?f~-~~- ... r' (Attach this transmittal to all contracts not prepared on the "Standard Contra^t" form.) :PPro~j2X-_~_ _____ Cou nty Cou nse ( /1 In I I to budget expenditure 02-12294-107 Rev. 5/76 , " . --~ . . AGREEMENT FOR PAYMENT OF JUDGMENT 1. Recitals: This agreement pertains to two lawsuits which were filed in the Superior Court of California, County of San Bernar- dino, entitled Walsh, et a1. v. State of California, et a1., action No. 199364, and George, et a1. v. State of California, et a1., action No. 209924. which were consolidated for trial. As used herein, "Plaintiffs" collectively refers to all those named as plaintiffs in the two lawsuits, save and except James Lynas and Shirley Lynas (collectively referred to as "Lynas"). The City of San Bernardino ("City") and the San Bernardino County Flood Control District ("District"), among others, were named as defendants in the above-entitled lawsuits. Following trial, judgment in the above-entitled lawsuits was entered in favor of Plaintiffs and Lynas and against the City and District in the amount of $4,089,629.46, including prejudgment inter- est, costs, and attorneys' fees, on or about June 24, 1986. Plaintiffs and Lynas were subsequently allowed additional post judgment costs and attorneys' fees in the amount of $11,691.88, for a total judgment of $4,101,321.34. The City and the District filed timely notices of appeal from the judgment and Plaintiffs and Lynas have cross-appealed. The parties now wish to provide for payment of the judgment in these actions and do mutually agree upon the following: 2. The City and the District shall pay the judgment in the following installments: (a) The sum of $181,544.00, representing that portion of the judgment recoverable by Lynas, plus interest thereon, shall be deposited in court on or before December 31. 1986, by way of an interpleader action pursuant to CCP ~386, naming Lynas and Brekhus & Williams as defendants. The amount of interest shall be calculated in accordance with the laws of the State of California pertaining to post judgment interest. (b) The remainder of the judgment shall be paid to Plain- tiffs in the following installments: $1,878.970.00 by City on or before December 31. 1986: $439,486.00 by District on or before December 31, 1986: $500,000.00 by District on or before June 30, 1987: $701.321.34 by City plus any accrued interest calculated in accordance with the laws of the State of California for post judgment interest on City's share as provided in paragraphs 4 and 6 of this agreement, no earlier than January 2, 1988, and no later than June 30, 1988. $400,000.00 by District plus any accrued interest calculated in accordance with the laws of the State of California for post judgment interest on District's share EHR: kb 12/8/86 , .' , . . as provided in paragraphs 4 and 6 of this agreement, no earlier than January 2, 1988, and no later than June 30, 1988. 3. The City and the District shall have the option, at either's sole election, to prepay any portion of any remaining unpaid balance due under this agreement at any time without penalty, except that at least $400,000.00 (including interest) of District's share and $600,000.00 (including interest) of City's share shall be paid after January 1, 1988. 4. The amounts referred to in paragraph 2(b), shall bear interest calculated in accordance with the laws of the State of California for post judgment interest from September 5, 1986, to the date of payment. Upon payment of each of the installments, interest shall cease to accrue on the amount of that installment. 5. District's share of the total payment set fort~ in para- graph 2(a) is $60,515.00 of principal plus legal interest on the District's share from December 1, 1986 to the date such funds are interpleaded. City's share of the total payment set forth in para- graph 2(a) is $121,029.00 of principal plus legal interest on the total principal balance ($181,544.00) from the date of judgement to the date the funds are interpleaded less the amount of interest to be paid by the District pursuant to this paragraph. 6. District's share of the total payments set forth in para- graph 2(b) is $1,339,485.00 of the principal plus interest calculated in accordance with the laws of the State of California for postjudg- ment interest accruing on the unpaid balance of District's share from December 1, 1986. City's share of the total payments set forth in paragraph 2(b) is $2,580,292.34 of the principal plus all accrued interest on the total judgement for plaintiffs less the accrued interest paid by District pursuant to this paragraph. 7. Upon receipt of each of the installment payments referred to in Paragraph 2(b), above, or payments under paragraph 3, Plain- tiffs, through their attorneys, shall execute an acknowledgement of partial satisfaction of judgment in favor of the City and the Dis- trict. Upon receipt of the final installment payments referred to Paragraph 2(b), above, Plaintiffs, through their attorneys, shall execute an acknowledgement of full satisfaction of judgment in favor of the City and District. 8. Upon full execution of this agreement, City and District, and each of them, shall dismiss with prejudice their appeals from the judgment in this matter, and Plaintiffs shall dismiss with prejudice their cross-appeal, all of which are now pending in the Court of Appeal of the State of California, Fourth District, Division Two. 9. The payments referred to in Paragraphs 2(b) and 3, above, may pe made by check payable to the trust account of the law firm of Brekhus and Williams, in trust for plaintiffs in Walsh, et a1.,v. State of California, et a1. and George, et a1. vs. State of Ca11fornia, et a1. It 1S expressly understood and agreed that City and District shall have no responsibility for the distribution of the payments referred to in Paragraphs 2(b) and 3, above, among Plain- tiffs and their attorneys and any third parties (including, but not limited to, the united States of America) who may assert any claim -2- ", . . 'thereto or interest therein. Plaintiffs and their attorneys ex- pressly acknowledge and agree that such distribution is the sole responsibility of Plaintiffs and their attorneys. In the event the City or District, or either of them, receives written notice from any Plaintiff(s) or their attorneys of any dispute between or among Plaintiffs, or between or among Plain- tiffs and their attorneys, save and except Lynas, the City or District, or either of them, at their sole election, may interplead into the Superior Court of California, County of San Bernardino, the amount specified in such written notice so long as that amount is less than that amount due under the agreement at the time the notice is given. Upon the filing of an action in interpleader and deposit into court of such amount due, the party filing the action in interpleader shall be deemed to have satisfied its obligations in connection with such amount. All the parties to this agreement understand that claims for moneys due under this agreement by third parties may be made in accordance with the laws of the State of California. 10. In the event there is any dispute over the terms and con- ditions of this agreement, in any litigation that is commenced concerning it, the prevailing party shall be entitled to recover its reasonable attorney's fees. 11. Plaintiffs and their attorneys acknowledge and agree that the consideration set forth in Paragraph 2, above, is accepted in full payment of the judgement filed on June 24, 1986, and the addi- tional post-judgement costs and attorneys' fees in the amount of $11,691.88. 12. Plaintiffs and their attorneys acknowledge that no promise, inducement or agreement, not herein expressed has been made to them, and that this writing contains the entire agreement between the parties hereto, and that the terms of this agreement are contrac- tual and not a mere recital. Dated: DEe 2;:: 1986 SAN BERNARDINO COUNTY FLOOD CONTROL DISTRICT BY'~~~~~ Chairman, Board of SupervisOrs Dated: I~ol/R ~ By: Dated: / J /;2/ 1"J6 . BRE:~S & -'LI':~~ ~.;//~~ -3- , '..~ . . , I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: .cP~ /.1' /9!?C- , ~ %A---/ PATRICK WALSH ~li~ Ikt./ ) .KATHLEEN WALSH -4- '" . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and Geor e, et al. v. State of California, et al. (San Bernardino County SuperIor Court case number 2 9924 : the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Da ted : ,:J-Is-If, ~--? AL TI'EZ ~ ~~/ (//d.u I LI A MARTI Z j -5- ", . . ,", I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 199364) and George, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: t,;}--\ ':, - 'Is' lo ~"1 A;;jQ~" CHERYL HELPS ~~>o~" -6- " . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and Geor e, et al. v. State of California, et al. (San Bernardino County Super~or Court case number : t e law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: SJ~7"..-f.lUv /0 J? RC; 'J) .~~ ~J f, ~~c'Lft,//J;~ D. G NE PE ETON CAROL J .{~ENDLETON -7- " . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. Dated: ~ /~/9& ~! J S ,8 . LIN vV ~~ JUD H HAMLIN )n.~ -9- " . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: /d-/~-U ORA WOLF CO~7' c~ ae:/" ALVIN WOLF tl -10- ',' '" . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: O.u. /3, /98(, ~ E ?3LM ROBERT E. BLISS JU~Ld:. ~ -11- . . . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and Geor e, et al. v. State of California, et al. (San Bernardino County Super10r Court case number ; t e law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. Dated:/Z-/t- C66 ~ ~RRIS B~ l!~h'/~~Jlh7A/ D LORES BO R -12- " . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: /J.. /1). ?(. fi'L~Gc~l A~~,~ GERALD GINI I ' , - -13- . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 199364) and George, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: ~to. IS; /9~'" -'h."'J VJ~ IRVIN HILL . ~~ MILDRED HILLER -14- . tt r/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 199364) and George, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: ~{-~ PEG -i2 -15- J ! " . '.. It . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924)1 the law firm of Brekhus & Williams1 the City of San Bernardino1 and the San Bernardino County Flood Control District. 13; If 6 ~ -16- " . , . . tt I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: /~ -I r - ,." A~I=E~~ ~~\:)~ LINDA DELORES PRESTRIDGE -17- '. . \ .' ~ II ~ I/we accept and agree to 'the terms and conditions of the Agreement for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, ,et al. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & 'Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. DATED: JAMES L. LYNAS SHIRLEY M. LYNAS NOTE: Action in Interpleader filed 12/30/86 S.B.S.C. No. 235810 -18- r I ,;' .. ~ . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 199364) and George, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: /;1. -/3 -S--c.. ~V~ STEPH BARILICS ~' ~ a~'0~.a/ L"1 A B~LIC~ -19- " . . ~ I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: Dee, .17] I q ~ ~~t0~ ~"-_.:' .'.:..... "-.":-.nL.:':-' PHILIP WEBER lM~ r: '~IYOKO WEBER -20- '. . . - I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. P&:f~;!;'!1~ -21- , . . , I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh. et al. v. State of California. et al. (San Bernardino County Superior Court case number 199364) and George. et al. v. State of California. et al. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. Dated: N 1\1 e(l~/ 2-' IS- ~b Ii VJEFF McCANLIES Executor to the Estate of Sherry McCanlies ttll1)",[J.~ -22- . . . , I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. Dated: rJ:.1/tr,) fh,./"/I) L VELLE COCHRAN -23- , . . , , I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and Geor e, et al. v. State of California, et al. (San Bernardino County Super10r Court case number 992 : the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: A ~\ V\....- JAMES . MOSS -+._u Z~~~) JU . MOSS -24- '1'.' , . . ClrwJ accept and agree to the terms and conditions of the Agree- ment f~payment of Judgment between and among Plaintiffs in Wals~. et al. v. State of California. et al. (San Bernardino County Superior Court case number 199364) and George. et al. v. State of California. et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: 1~~ GILBERT FILLMORE -25- , , ' . . . r/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924)1 the law firm of Brekhus & Williams1 the City of San Bernardino1 and the San Bernardino County Flood Control District. Dated: ~///JQgA,~ A. ours SC EPP dRY) :! ~.pp .),.- h ~r'j- ;;. -26- . , '. . . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 199364) and George, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. Dated: ~~~ ..L# i - -" t~~~' -27- I . /'2 . .Ie.' ",.C r' . , . . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and Geor e, et al. v. State of California, et al. (San Bernardino County SuperIor Court case num er 9 : t e law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: ~~.~~ MARY BONTE -28- I. . . I/we accept and agree to the terms and conditions of the Agree- .ment for Payment of Judgment between and among Plaintiffs in Walsh. et a1. v. State of California. et a1. (San Bernardino County Superior Court case number 199364) and Geor e. et a1. v. State of California. et a1. (San Bernardino County Super10r Court case number 92: t e law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: ~~~ei:J ~",\.~ J ~ . CREWS ",,- \"'1..- \~ _~\p -29- , I. .. . . X/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: ~..u.. ./~ /9&'(" ~~u~ e. DEVAUGHN ETERSilN .L- Q~---- () nl ~ L::t.~a~ . :---' ~--". COLLEEN PETER EN -30- ... . . I. I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 199364) and Geor e, et a1. v. State of California, et a1. (San Bernardino County Super10r Court case number 2: the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: ~-.~I I dfL2-- . .<~ tf5-n-A . MAREDITH BOMBERGER /9?C- 1L-<...- -31- . ''- . . I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et a1. v. State of California, et a1. (San Bernardino County Superior Court case number 199364) and Geor e, et a1. v. State of California, et a1. (San Bernardino County Super10r Court case number 209924 : the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: ) - -32- ~ . . I. I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & Williams; the City of San Bernardino: and the San Bernardino County Flood Control District. Dated: f24 d~h~ RITA GEORGE d' Executor of the Estate of HAROLD E. GEORGE ERESA GEOR Executor of the E HAROLD E. GEORGE -33- ~ . . ,. , . < X/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and Geor e, et al. v. State of California, et al. (San Bernardino County Super~or Court case num er 9 ; t e law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. Dated: 1;7-1 :>--&h ( "/L~~~~k JOHN LEO RD, X II BE~~ -34- " , . a 'I. . ~ . . , I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924); the law firm of Brekhus & Williams; the City of San Bernardino; and the San Bernardino County Flood Control District. Dated: l;t-I-:Y-~ :-~~~L ~BERT MccuLL1S6cfH - ? ~~f}Jt~ -/4 IK MaC L I -35- .~ . ..., . e . '. I/we accept and agree to the terms and conditions of the Agree- ment for Payment of Judgment between and among Plaintiffs in Walsh, et al. v. State of California, et al. (San Bernardino County Superior Court case number 199364) and George, et al. v. State of California, et al. (San Bernardino County Superior Court case number 209924): the law firm of Brekhus & Williams: the City of San Bernardino: and the San Bernardino County Flood Control District. , ~ C. fii{e-PZ--I'C< RdTH C. PFLAN R C1 r!:..u-<- /? /7"?'c' ,/ -36-