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HomeMy WebLinkAboutContracts & Agreements_10-1992_CCv0001.pdf SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release is made and entered into this 10th day of March, 1992 by and between Metropolis Construction Company, Inc. , a California Corporation; Mader Investors, Ltd. ; and Mader Special Situation Investment Fund, a Florida Limited Partnership (hereinafter collectively referred to as "Mader") and the City of Redlands, a municipal corporation (hereinafter referred to as "City") . RECITALS WHEREAS, Mader received City approval of a conditional use permit ("CUP 46011} for the construction of a 152 unit multifamily development project located at 1151 West Wabash Avenue in Redlands, California (hereinafter the "Project") ; and WHEREAS, in connection with the processing of CUP 460 and development of the Project, Mader paid to City the sum of One Million Three Hundred Eighty-Eight Thousand Dollars ($1,388,000.00) towards certain processing, plan-checking, capital improvement, building permit and other fees required by City (hereinafter the "Fees") ; and WHEREAS, the Fees do not include any amounts paid by Mader to the Redlands Unified School District (the "School i DJM98851 District") for school impaction fees, which have since been returned by the School District to Mader; and WHEREAS, in addition to payment of the Fees, City also required Mader to pledge to City a Certificate of Deposit ("CD") in the amount of $103 , 000.00 which City has since held as security for improvements associated with the Project; and WHEREAS, Mader alleges that in the event development of the Project was terminated by Mader, that the Fees and the CD should then be returned by City to Mader; and WHEREAS, on or about September 4, 1991 Mader notified City that it considered its Project terminated and demanded a return of the Fees and the CD; and WHEREAS, on or about December 12, 1991, Mader filed a Writ of Mandate with the San Bernardino County superior Court as Civil Action Number 268286 (the "Lawsuit") and, subsequently, a Preemptory Writ was issued on January 13 , 1992 ordering the return of the Fees and the CD as well as issuing an accounting thereof (the "First Order") ; and WHEREAS, on or about February 13 , 1992, the Court vacated the First Order and issued an Alternative Writ of Mandate (the "Alternative Writ of Mandate") stating: DJM98851 -2- "NOW, THEREFORE, the City of Redlands is commanded immediately on the receipt of this writ to (1) account of the petitioners' fees, permit payments and collateral and (2) return to the petitioners 1.388 million dollars in fees, permit payments and collateral. IN THE ALTERNATIVE, the City of Redlands must show cause before this court at the Department 11611 of the Superior Court of California, San Bernardino County, Central District, 351 N. Arrowhead Avenue, San Bernardino, California 92415-0240 on March 20, 1992 , at 8:30 a.m. , why it has not (1) accounted for the petitioners' 1.388 million dollars in fees, permit payments and collateral; and (2) returned the 1.388 million dollars in the fees, permit payments and collateral. A peremptory writ shall be issued in the Court finds that the City of Redlands has no cause to hold the petitioners' fees, permit payments and collateral. " WHEREAS, because USA Property Fund, Inc. , a general partner for Wabash Apartments, L.P. (hereinafter collectively referred to as "Buyer") proposes to enter into an agreement to purchase the Project and the real property which is the subject of the Project (the "Purchase Agreement") , Mader and City have entered into this Agreement to settle the Lawsuit and avoid further court action regarding return of the CD and the Fees for the Project; and WHEREAS, Mader and City acknowledge that the four following agreements must be executed to complete the purchase of the Project by Buyer and carry out the terms of this settlement: (1) this Settlement Agreement; (2) the Waiver Agreement attached hereto as Exhibit "A;" (3) the Tri-Party Agreement attached hereto DJM98851 -3- and attorneys' fees involved in the prosecution or defense of the Lawsuit. 4. Payment of Fees. City and Mader agree that City's reimbursement of the Fees to Mader shall be made in accordance with the terms and provisions of the Tri Party Agreement attached hereto as Exhibit 11B, 11 provided, however, in the event that Buyer fails to obtain City approval for construction of its proposed development project or otherwise fails to construct its development project by December 31, 1992, City shall reimburse the Fee to Mader on January 2, 1993. 5. Return of Q. The CD shall be returned to Mader in accordance with the terms and provisions of the Waiver Agreement attached hereto as Exhibit IIC.11 6. Further Acts. Mader and City agree that at any time, or from time to time, after the effective date of this Agreement, each will execute and deliver such further documents and do such further acts and things as the other party may reasonably request in order to carry out the purposes of this Agreement. 7. Effort of Agreement. The representations, negotiations, statements or any other facts associated with the process leading up to the execution of this Agreement shall not be used by Mader or City in any subsequent litigation should this Agreement terminate. DJM98851 -5- as Exhibit IIBII and (4) the Purchase Agreement attached hereto as Exhibit 1IC;II and WHEREAS, Mader and City have further entered into this Agreement to unequivocally establish the amount of Fees in controversy in the Lawsuit at One Million Three Hundred Eighty- Eight Thousand Dollars; NOW, THEREFORE, in consideration of the mutual covenants contained herein, Mader and City agree as follows: AGREEMENT 1. Recitals. The foregoing recitals are true and correct and are hereby incorporated into this Agreement. 2. Effective Date. This Agreement shall become effective on the date the Purchase Agreement is executed by Buyer and Mader. 3 . Dismissal of Lawsgit. Within three (3) days after the effective date of this Agreement, Mader shall file with the Superior Court of San Bernardino a dismissal of San Bernardino Superior Court Case No. 268286 in the form attached hereto as Exhibit I'D." A true and correct copy of such dismissal shall concurrently be delivered to City in accordance with the provisions of paragraph 11 hereof. The parties agree to bear their own costs DJM98851 -4 8. Binding Effect. This Agreement shall be binding upon and inure to the benefit of each of the parties hereto and to their respective successors and assigns. 9. Time. Time is of the essence in this Agreement. 10. Counterparts. This Agreement may be executed in any number of counterparts, all of which taken together shall constitute one and the same instrument. 11. Notice. Any approval, disapproval, demand or other notice which either party may desire to give to the other party or the Escrow Holder shall be in writing and may be given by personal delivery, or by mailing the same by registered or certified mail, return receipt requested (or by telecopy if followed by one of the aforementioned methods) to the person to whom the notice is directed at the address of such party hereinafter such forth, or such other address as the parties may hereafter designate: TO CITY: City of Redlands c/o City Manager 30 Cajon Street Redlands, CA 92373 COPY TO: Best, Best & Krieger 400 Mission Square 3750 University Avenue Riverside, CA 92501 Attn: Daniel J. McHugh DJM98851 -6- TO MADER: Mader Special situation Investment Fund c/o Reger Capital, Inc. 2730 Transit Road West Seneca, NY 14424 COPY TO: Kritzer, Blankenship & Weil 650 E. Hospitality Lane, Suite 560 San Bernardino, CA 92408 Attn: Mark I. Blankenship TO BUYER: Wabash Apartment, L.P. 3179 Temple Avenue Suite 170 Pomona, CA 91768-3241 COPY TO: Aubert & Hanna 1888 Century Park East, Suite 908 Los Angeles, CA 90068 Attn: Ronald D. Aubert All notices are deemed received only upon the earlier of actual receipt by the party to which the notice was intended, or 48 hours after deposit in the United States Mail. 12. Modification. This Agreement shall not be modified except by written document signed by each of the parties hereto. 13. Authority. Each person executing this Agreement does hereby personally represent and warrant to the other signatories that he/she has the authority necessary to execute this Agreement and that no other consent or approvals of anyone are required or necessary for this Agreement to be so binding. DJM98851 -7- 14. Governing Law. This Agreement shall in all respects be interpreted, enforced and governed by and under the laws of the State of California. 15. Fair Meaning. This Agreement has been jointly negotiated and drafted. The language of this Agreement shall be construed as a whole according to its fair meaning, and not strictly for or against any of the parties. 16. Attorneys' Fees. Should any party hereto reasonably retain counsel for the purpose of enforcing or preventing the breach of any provision hereof, including but not limited to instituting or defending any action or proceeding to enforce any provision hereof, the prevailing party shall be entitled to be reimbursed by the losing party for all costs and expenses incurred thereby, including but not limited to reasonable attorneys' fees. 17. Entire Agreement. This Agreement, and the exhibits attached hereto, constitutes the entire agreement of the parties hereto as to the matters contained herein. 18. Mader Release. Mader, on its own behalf and on behalf of its agents, attorneys, heirs, representatives, executors, successors and assigns, hereby releases and forever discharges city, its councilmembers, employees, attorneys, agents and representatives of and from any and all claims, causes of action, actions, damages, losses, demands, accounts, reckonings, rights, Dim98851 -8- debts, liabilities, obligations, disputes and controversies of every character and kind, known or unknown, suspected or unsuspected, existing or contingent, latent or patent, asserted or not yet asserted, which Mader may now own or hold or at any time owned or held, or shall or may hereafter own or hold arising out of or in any way connected with any fact, matter or thing whatsoever occurring that is in any way related to the subject matter of this Agreement. 19. City Release. City on its own behalf and on behalf of its councilmembers, employees, attorneys, agents and representatives hereby releases and forever discharges Mader, its agents, attorneys, and representatives, of and from any and all claims, causes of action, actions, damages, losses, demands, accounts, reckonings, rights, debts, liabilities, obligations, disputes and controversies, of every character and kind, known and unknown, suspected or unsuspected, existing or contingent, latent or patent, asserted or not yet asserted, which City may now own or hold or at any time owned or held, or shall or may hereafter own or hold arising out of or in any way connected with any fact, matter or thing whatsoever occurring that is in any way related to the subject matter of this Agreement. 20. Advice of Counsel. Mader represents and warrants that it has sought the advice and counsel of its attorneys and it is relying solely on such advice in entering into this Agreement. DJM98851 -9- 21. venue. Any action commenced to enforce or interpret the terms or provisions of this Agreement shall be commenced and maintained in the courts of the State of California. METROPOLIS CONSTRUCTION COMPANY, INC. ATTEST: By: Clerk of the Board President of the Board of Directors MADER SPECIAL SITUATION INVESTMENT FUND By: General Partner MADER INVESTORS, LTD. By: General Partner CITY OF REDLANDS ATTEST: By: City Clerk, City of Mayor, City of Redlands Redlands 4JM98851 -10- f • i w TRa PARTY AGREEMENT i 1"his Tri Party Rgrarsment { g "h' '- "A reempt�t" ) is mada by and between the City of Redlands, California ( the "City" ) , Mader Special Situation I vast~e^t Fund, a Florida limitad part-nership ( the "C";ner" ) and Wabash ; Apart-mGntsf L.P. ( "Suyerl ) . R E C I T A L S A. The purpose of this Agreement is to provide affordable housing apartment-, rental units in the City to affOCtuate the General Plan Cf the City. This Agreement is entered into for the pity p sa of developing the P+oparty, as hereinafter identified, to a 152 unit apartment protect and not for speCulat;on in lard holding and to settle certain contested matters between the City and C:»nar. This Agreement ie int the vital and the bast .interests of the City and the health, safety and welfare of its residents, and in accordance with the public purposes and provisions of applicable state and local laws and rcquirer+^.ents . a . Owner is the owner of that certain real property locat(d on the no,thwest Corner of Wabash and Brockton Streets in the City which real. property ( the "Property" ) is more particularly described in Exhibit A attachod hereto and incorporated herein by reference. C. Owner has obtained an Alternative Writ of Mandate ( th'a "Writ" ) againSt tha City issued by the Superior Court of the County of San Bernardino. D. Owner and Buyer will enter into an agreeman4 ( the "Purchase Agreement" ) wherein Owner will agree to $all and BuYer will nreo to buy the Property on the terms and conditions therein E. Buyer desiras to construct a 152 unit affordable housing apartment project ( "Buyer ' s F+olect" ) on, the Property. The City desires to have the Buyer's Project constructed to Yelp meet the needs for providing affordable housing within the City. F. Buyer ' s Project will not be economically feasible without the City's o:ttering into this Agreement, and the, City is willing to enter into this Agreement for the benefit to be derived by the Cit; from Buyera Prcl ec t. WE*F0RE, i.i Con3.'...de. ation of the premises, the parties agree as fc,Llo s: i I A v R E E iv E N T ` t 1 . The City shall pay to B,uyar as a subsidy t,:w rd BFjyafi' b Froject the surf of S250, OOC of March 11, 1992, provided that Buye and owner have entered into the Purchase Agreement. If Buyer and RVT-rXUSA.CUR ---------- ik------ - - - - - 1 $aller have not entered into the FurchIse Agreement on or befoJe 9, 1992, this Agreement shall thereupon terminato witho further liability of the parties . lZir the City pays said $250,000 to =-,,;yer as hazeinabove pro-vided, Buyer Shall deposit Said funds in the EsCrC-d PtOvided for in. the Purchase Acreament within ens tusina23 day after recaipt by Buyer of said funda whiCh the Escro'w Poider —4 shall release to Owner upon receint thereof in a:cOrdanc14 l with the tefir- S 046 the Purchase Agreement. In no event shall Buyer tI i� ilabie for the return of said $250, 000 to the City or any other Pa r i-y- 2 . V*e City ack7cwjed3e5, represents and warrants to BluYe'r thathe total fees ( "Buybr ' s Fees" ) shown on Exhibit B attac.^.e hereto and incor-orat-ed herein by reference are all of the fecs or charges payable by Buyer to the City for tha developin-ant end ci��nstructlf.on, of Euyer I s Project. Said Buyer' s Feel inclvda but ara not limited to, fees or charges for sewer or water Service, except for the actual COnsunmrj-,tion charges for water or service fees fol sewer, but, :not including Connection fees which have been paid . V,4 City further acknowledges that in order to make Buyer' s proJGA economically feaiibla, Buyer plans to revise the floor plans of tll".si Prb.Ject to provide a mix of one and two bedroom units together wit3 a mini'llum of forty eight ( 48 ) three (3 ) bedrocm apartment units`, provided that tho revision of the floor plans and mix will not enlarGo tho footprint of the buildings from that provided for ipl. Owner' s Project. Said chango in units, M4.X and addition of thre0 ( 3 ) bedroom apartment units constitutes a change from the Ownar's 3 , Buyer shall, 1-11)0n tha close of tha Escrow provided for In the P�irctlasa Agreement and the recordation of a dead of trust securing ,Yer's CCnStruCtioa Loan in the Official Records of Sari Bernardino County, California, pay to the City in immediately available funds Buyer' s Fe0s, The City upon receipt of Buyor'4 Fees shall pay $1, 118, 000 to Cwner pursuant to an agrooment ( tho "settlement AgFreef,-,on+.-" ) tatween Owner and City made on even dat4 hereof a copy of which is attachad hereto as Exhibit C' Notwithstanding anything contoined in this Agreement to tho cont-6-y, if the City rias riot paid to the Owner $1, 138,000 p-ursv4nfi to t"G terms Of the Settloment- Agreement on or before December 31,,, 1992, then this Aarae,-,ent shall thereupon automatically terminat4 and, ha no further forco or affect. "Construction Loan" as used n herein shall mean a loan to 81.Iyer in an amount not ies3 than; $e, 250,000, having a term of not less than ona ( 1 ) year, bearing interest On the Unpaid prinoipal balance of not mora than two (2) points over the sander' s prime rate of ip.terest, and being secured by a first deed of trust on the Property and AnU76-r' O Project. 4 . INOtwithstand-Irig anything to the contrary herein, tnJ P3rt' e'j ackriCwledge and agree that Buyer' s obligation to construct the Buyer' s Project is expressly Conditioned on: RVT?KUSA.CUR 030,992 2 a the economic feasibility of BuYarts PrOJect as dete.-7n-drod by B%;ye-- in its reasonable distr0tiOn; I MIS b. Buyer' s Obtaining the Ccn$.,-ruction Loan or, tar ! it; C . R1,yer s obtaining a ICan Cf at least the State of California Departmant C44 and Community -6 program which loan Devel.opment Rental Housing Construction p1b. r, _I -ordinate to t?la .,,all be SeC,'�red by Buya a pro4eCt and siit J - -y to i*- Lcr.StCzraction Loan or, teres reaScnab' Y Sati,$fa d. puyarls obtaining at least $12, 500,000 in ax credits pursuant to section 42 c= the ate=nal Ravariue Coda from the California Tax Credit Nilscaticr" CCMon�-4ttGO tOr m s reasonably ,satisfactory to it. 5. The partial hereto agree that at any time or from time to time after the execution of this Agreement they will , Up8n req,-,asIC. of the ether, execute and daliver such further docu-mantg and do such further acts and things as such party may roasonabill req,-;est in order to effect fully the p�irposai Of this Agreement: 6 . This Agreement shall be bindinc upon and inure to t)a benefit of each of the parties hereto and to their raspective successors and aisiGns , 7. This Agreement may be executed in any nuMb,0 r of counterparts, but all of which taken tcga�I-ersha3 Z constitute orie and the same inztrumant . 8 . ,rime is of the essence in this At-fe6m0nt. 9 . Any approval, disapproval, demand or ether notice which, eithar party may d*sire to give to tli"G Other Party Or to E$cr6w Folder must be in writing and may be given by Petsonal delivery, air courier or by mailing the same by re3ilst4rad or certified mail, return receipt req,,;estad (or by telecopy if followed by one Of t�lie aforementioned methods) to the party to whom the notice is directed at the address of such, :arty hereinafter set fcr-'-.-.h, or such oth4r address as the parties may hereafter desll.,�natel TO CITY; City of pedlands c/o City YanaSa.- 30 Cajon Straet Redlanda, CA 92373 WITH A COPY TO: Best/ Best 9, yriavr 400 Mis4ion squara 3760 university Avenue Riverside, California 92502 Attn: Daniel J. McHugh RVTPKUSA.C'OR 030992 - --------- - To GWN---R: Bader Special situation Invest-..ant FvnC, a Florida limited partnarship C/o Regar Capital, Inc. :2730 Trans.-it Road West Sene,~a, re 14424 Mark Bilanke.-ship 6150 E. Hospitality Lane Suite 5519 San Bernardino, California 92408 TO 5 U-i EIR Apart:r.ar�ts, L . P. Pomona, CA 91768-3241- WITH A COPY TO: Aubert a Hanna, P, C. 1388 Century Park East, Ste. 908 Los Angeles, CA 90067 Attn: Ronald D . Aubert, Esq. Telecopy No. ( 213 ) 556-8799 TO E$C,,R'-"W FGJLDER: Chicago Title Insurance COM.Oar-Y 1717 Walnut Grove Avenue RcsemeaO, CA 91770 All notices are deemed received only upon the earlier of actual receipt by the party to which the notice was inte.nded or 48 houra from deposit in mail or with courier. jo. The laws of California shall govern the interpretation, and effec-C of this Agreement. 11 , No provision of Vii$ A�reemant Is to be interpreted for or against any party be"Vaosa that party or that party' s legal representative drafted the provision, No provision or breach of. any provision of this Agreement can be waived unless in writing.; Waiver of any breach of any provision is not a waiver of any other. breach of the sane provision oA- any other provision, 12, in tho event of any action or preceeding by any party� hereto for breach of or to enforce the Provisions of . thij;' Agreement, the prevailing party in such action or proceeding shall; be 9,-,1-1 fled d to recover reasonable attorneys' fees and Coate as the court may de*qr-mine . The pa-etiia!j agree that the vonue for Gvlch', action or P,Cc94dirLg shail be the state of California . 13 . The Reolitalg set fcrtj% ejoo.,pe are hereby incorporated into, the body of this• Agreement; by this reference and made a part! RVTP,KUSA-CUR 030992 IN WITNESS WHEREOF, the parties herolCo have duly executed thi,4 XgrGemant as of 1992 . CITY Cv. REDLASOS : XADZER SFCCIAL SITVATION INWESTMENT FUND, a Florida limited Vartner4hip By: CQneral Partner WABASH APARTMENTS, LvF . By: USA Properties Fund, InC, , General P ler .By. RVTPKU$X. CUR 03M�2 ----------- ----------------- LIST OF EXHIBITS Exhibit A LeSitl Description Approvals it Exhibit C r(l;TPKvSA,CUR 0,3CS92 -------------------------------------- ------------------------------ order ZZ'o. 9200002 —01 Pada I EXH134'T A - LEIGAL SOU---* 651.2 7.ZV�17 OF EAST 6EO.7 F77- OF THE NCR,�*H 1322.5 rrr— 07 THE so".7-HZAS: l f4 OF SECTION 24, TOwNSH-_? 1 SOUTHP-ANG-_ 3 Wr.ST, SAN BASE AN:) XZROIAN, 7 IN T6 C:':y OF RZOLA2,0S, ACCOR,�, '_�Sa TO THE FLAT OF SA-7D LAND APPROV--ml BY T'.-.E SURVEYOR GrN-_-R.AL, DATE, rEBRUARy 19, 1869, DESCR:3rD AS FOLLOWS: BEG.7NNiNG A-- A POINT IN TH-T M*_r0ZLE LINE OF WABASH Vvl:;UZ, SAID POINT BE"NG 50Uh C' 23 ' EA T 670.3 FEET FRCIM A-N IRON ROD AT THE I N T_TR S Z C-_:0 N O.`z' TLINES OF L" N:A AND WASASH AVENUES! THENCE FROM THIS POINT OF _N _NG ALONG THE M--O:L:-: L:NE OF WABASH AVENUE, 25 ' EAST 652-2 FEET TO :H_v INTERSECTION OF THE X=CLS LINE OF WABASH AV :NUE AND N CE AVENUE; THENCE ALONG THE u_'rDDl _17_ LINE OF SAID NICE AVE-SUE, SOUTH 89* 30' WEST 660.7 FEZ THZENCE NORTH 0* 25' WEST. 652.2 FE-v'.r'/ THENCE NORTH 893 30' EAST 660.7 FEET TO THE POINT OF BT-OINN'_rNG, BEING LOTS 15 AND PORTION OF LOTS 9, 10 AND 14 IN BLOCK I Or FUBBARD'S TWO AND CNE-HALV ACR.Is ADDITION TO KENTONTZ AND PORT'.014 OF NICE AVENUE (NOW CLOSED) , AS RECORDED IN BOOK 5 OF YAPS, PAGE 43, RECOR:S OF SAID COUNTY. ,Tvr-'E?T.ING THER-TFIROM. ANY PORTION Lv.T_NG W IT F I N WA it!ASH A VE N TIT E, 80 FS Ec T 1,1-4 W, 0 T H ALSO EXCEPTING THEREFROX TFAT PORTION, IF ANY, LYING NORTHERLY 0.7 THE SOUTHERLY LT-N-7, ' AND ITS EASTERLY PRi6LOONCATION THEREOF, OF PARCELFLAP NO. 6134, AS SH WN BY KA?-014 FILE IN BOOK 61, PAGES 96 AND 97 OF PARCEL MAPS, IN THE OFFICE OF THE COUNTY ?_-COR:ER OF THE COUNTY OF SAN BERNAR.DINO, STATE OF CALIFORNIA. EXH`.*31.T "S" 70 RT_-PARTY AGREEMENT Ali ?Patton , permit , processing and inspection fees shall e Said fees shall include but not be limited to Tr-io=::t Fees ann 1 n(:z . ............ S t r,e a-t ol i,-s t r u c t, r Conditional Use Review , raT I IC t-a 11 ff - Signal Erv4ronment Assessment S t c r r",, "rai ^ Cor mission Review Process Fire Szzaticn Subsidized Financing New Fire Stations peques,!-, Ire Station #3 Pot ice Station Ltrary Ci t y 1- a1 City Yard Public Works Fees Water Source Acquisition. Water F r,:n tage Water Capital Improvement Sewer 'r"r-,*i n t A-g e Sewer Ca;Dital Improvement Solid Waste Capital Improvement improvement Agreement Process Trr,prove.ment Plan "heck Buj1ding Department Fees Plan Check Fee Valuation Permit Valuation CCIm"mer-c- a", SMT Seismic Plan Check Electric Permit Issue Electric Square Footage Charge P',,,.,mb4n- Permit issue P ".1 b n g Square Footage Charge Viecrani :al Permit Issue Mechanical Square Footage Charge Apartment Park/Open Fee Chi S-o c s a I F e a General Plan Review Wcro-Filrr Charge Electric Service >200A Electric Service > 41 0 0,C)A NE Plan Review SE Plar Review Additional Plan Check Fee Hourly Fire Department Fee Fire Department Plan Check Fee for sprinkler plans Fire Department Site Inspection Fee Parks and Recreation Fee WAIVER AND RELEASE AGREEMENT This agreement is made and entered into 10th_ day of March, 1992, by and between the City of Redlands, a municipal corporation (hereinafter "City" ) and Mader Special Situation Investment Fund, a Florida limited partnership (hereinafter "Mader" ) - RECITALS A. Mader is the owner of certain real property located at the northwest corner of Wabash and Brockton Streets in the City of Redlands which is more particularly described in Exhibit "A" attached hereto and incorporated herein by this reference (the "Property" ) . B. Mader is the successor in interest of Metropolis Construction, Inc. and Mader Investors, Ltd. who, along with Mader, proposed to construct a 152 unit multi-family housing development project ( "the Project" ) on the Property. C. In connection with its proposed development of the Property, Mader's predecessor in interest (Mader Investors'Ltd. ) deposited with City a certificate of deposit in the amount of $103,000.00 as security for the proper grading and construction of the Project. D. Mader has requested City release the Certificate of Deposit to Mader, and City has agreed to do so in accordance with the terms of this Waiver and Release Agreement. AGREEMENT NOW, THEREFORE, in consideration of the mutual promises contained herein, and for other good and valuable consideration, the receipt of which is hereby acknowledged, Mader Special Situation Investment Fund and the City of Redlands agree as follows: 1. Release of Certificate of Deposit. Upon Mader's execution of this Agreement, City shall immediately release to Mader the Certificate of Deposit in the sum of $103,000.00 which was given to City by Mader Investments Ltd. as security for the Project. 2 . Waiver and Release. Mader, on behalf of itself, its predecessors in interest, successors in interest and assigns hereby fully release City, it elected officials, officers, agents, employees and attorneys from any and all claims and -2- causes of action by reason of any damage which has been sustained, or may be sustained, as a result of or arising out of any work performed by Mader, it predecessors or successors interests, agents and employees, on the Property, including, but not limited to grading, and damages and loss resulting from storm water flows across the Property. Mader acknowledges and agrees that this waiver and release applies to all claims that Mader may have against City for injuries, damages, or losses to Mader' s person and property, real or personal, whether those injuries, damages or losses are know or unknown, foreseen or unforeseen or patent or latent. Mader expressly waives for itself and it predecessors and successors in interest, any and all right it other might have pursuant to California Civil Code section 1542 . 3 . Legal Authority Mader and its legal counsel have represented to City that Mader is the owner of the Property, that Mader has full authority to take receipt of the certificate of deposit and the undersigned, on behalf of Mader, has the authority to execute this Agreement. City has specifically relied upon these representations in entering into this Agreement. 4 . Indemnity. Mader shall defend, indemnify and hold City, it elected officials, officers, employees and attorneys free and harmless from and against any and all claims, losses, damages and causes of action, including attorneys ' fees, arising out of or in connection with City's performance of its obligations under this Agreement. -3- 5 . Attorneys' Fees and Venue. In the event any action is commenced to enforce or interpret the provisions of this Agreement, the prevailing party shall, in addition to any costs or other relief, be entitled to recover its reasonable attorneys ' fees . Any action related to the enforcement or interpretation of this Agreement shall be brought and maintained in the Court of California. 6. Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the State of California. -4- EXECUTED in San Bernardino County, California MADER SPECIAL SITUATION CITY OF REDLANDS INVESTMENT D BY: May r,, - t o an s On Behalf of its General Partner: ATTEST: Cay--c erk, Ct7f �edlands -5-