HomeMy WebLinkAboutAgr 2008-08-28 (Harris)
SETTLEMENT AGREEMENT AND
MUTUAL GENERAL RELEASE OF CLAIMS
This Sett\em~nt Agreement and Mutual General Release of Claims ("Agreement") is entered
into as of 1\ \~ us-l ;;;L'i' .2008 between the Town ofTihuron. a municipal corporation
("Town) and arns & Associates, Inc., a Cahtorma corporation ("Hams 'j. The Town and Harris are
collectively relerenced as the "Parties."
RECITALS
I. The Town of TibufOn appointed Harris as project engineer for the Lyford Cove
lJndergrounding District by Resolution No. 15-2003. dated May 2\,2003 ("Project Contract").
2. On May 17, 2007, Harris submitted to the Town a claim tor additional work
beyond the scope of the Project Contract ("Additional Work Claim"). !-I,mis claims that the Town
owes it an additional $93344 (ninety-three thousand three hundred torty-tour dollars). The
Town denies that it owes this sum.
3. In the interest of resolving this dispute without avoiding costly and protracted
litigation, the Panics have agrecd to settle the above-described dispute on the teons set torth in this
Agreement. On July 16. 2008. the Town Council considered the proposed settlement in closed
session and authorized the Town Manager to execute this Agreement
AGREEMENT
The Town and Harris, in consickration of the mutual covenants of this Agreement.
hereby agree to the following terms and conditions:
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1.
The Town will pay to Harris the additional sum of $64.944.50 (sixty-tour
thousand nine hundred tlJrty-tour dollars and tiny cents) tor the release of all
claims relating to or arising tram the Project Contract that Harris may have
against the Town.
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Harris and the Town hereby fully and forever discharge and release each other
ti'om any and all claims and causes of action, whether nO\~ known or now
unknown, including, including without limitation, attorneys fees and costs. which
the Parties have against each other arising out of the Project Contract and/or the
matters described in the Additional Work Claim.
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This Agreement includes an express waiver of Civil Code section 1542, which
states: A general release docs not extend to claims which the creditor docs
not know or suspect to exist in his or her favor at the timc of exccuting the
release, which if known by him or her must have materially atTl'cted his or
hcr settlement with the debtor,
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Harris (init.)
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Town (init)
4.
The Parties understand and agrce that this is a compromise settlement agrecment
of disputed claims, and that the execution of this Agreement shall not constitute or
be decmed or construed as an admission or liability on the part of any of thc
Parties.
5.
The Parties acknowledge that they have been rcpresented in the preparation orthis
Agrecment by the below-listed counsel. The Parties further acknowledge that
they havc read this Agreement and that they are fully aware of its intent and its
legal etfect and they have not been influenced to any extent whatever by any
representations made to them by each othcr. The Parties further represent that
they participated in the negotiation of this Agrecment and that it will not be
interpreted against any of them as the draftspcrson in the cvcnt or a disputc about
this Agreement
6.
Each party shall pay and be rcsponsible tor payment of thcir own attorney fees
and costs incurred with respect to the Project Contract and Additional Work
Claim and the preparation of this Agreement and in fultillment of its terms:
however, if any action or arbitration proceeding is commcnced to enforce or
interpret any tcrm or provision of this Agreement then thc prcvailing party in
such action shall be entitled to his, her or their reasonable attorney fees, costs and
necessary disbursements, including without limitation expert fees and costs,
mediation and arbitration fees, and the likc, incurred in such action or arbitration
proceeding.
7.
This Agreement represents the sole and cntire agreement betwcen the Parties
hereto and supersedes all prior agreements. negotiations and discussions among
them with respect to the subject mattcr covered hereby. Any amcndment to this
Agreemcnt must be in writing and signed by the authorized representatives of the
parties hereto.
8.
This Agrcement may be cxecuted in counterparts, cach of which when so
cxecuted shall be deemed an original. and this Agrecment and all signed
counterpUl1s shall constitute one and the same instrumcnt.
9.
This Agreement is decmed executcd on the date tirst written above.
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Any provisions of Evidence Code section 1152.5 notwithstanding, this Agreement
may be entorced by any pal1y hereto by a motion under Code of Civil Procedure
section 664.6 or by any other procedure permitted by law in the Superior Court of
Marin County.
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II. Th~ laws of the State of California shall govern the construction and enforcement
of this Agreement.
HARR S & ASSOCIATES
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y Erickson, President
TfIE TOWN OF TlGlIRON
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Margaret A. Curran
Town Manager. Town of Tiburon
By:
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APPROVED AS TO FORM
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Ann R. Danforth. Esq.
Town Attorney, Town ofTiburon
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