HomeMy WebLinkAbout20180508_SettlementAgreement_NewHeritage_TwinCreeksSETTLEMENT AGREEMENT
AND GENERAL RELEASE OF CLAIMS
This Settlement Agreement ("Agreement") is entered into this f, duty of May. 2018 (the
"Rffec Live Da to") by the City of San Luis Obispo, a municipal corporation and charter city ("City")
and New Heritage Fainily Limited Partnership, a foreign limited partnership ("New Heritage")
(City ,and New Heritage are collectively referred to herein as the "Parties").
Recitals
WHEREAS, on February 5, 2018, the City's Architectural Review Committee approved New
Heritage's Twin Creeks mixed use project ("Twin Creeks") which consists of 94 apartment units,
2,463 square feet of indoor residential amenity space, outdoor residential amenity space, and 3,488
square feet of commercial space; and
WHEREAS, on February 13, 2018, New Heritage appealed the Architectural Review
Committee's approval of "Twin Creeks due to the inclusion of Condition of Approval 31.d) (the
"Condition"), which reads:
Prior to issuance of building permits, the applicant shall pay City the documented
costs for reimbursement of the frontage improvements that were completed along
Orcutt Road adjacent to the property. Such costs include City Transportation
Impact Fees that were used to advance these public improvements required for the
project. The final amount will be subject to the approval of the Public Works
Director.
WHEREAS, New Heritage alleges that the Condition is an illegal exaction under California law;
and
WHEREAS, the City disagrees with New Heritage's analysis of the Condition; and
WHEREAS, by this Settlement Agreement, the Parties desire to resolve the dispute by agreeing
to all the specific amourits payable by New Heritage to the City under Condition 31.
Agreement
NOW, THEREFORE, in consideration of the mutual promises and covenants contained herein
and other good and valuable consideration, the sufficiency of which is hereby acknowledged, and
intending to be legally bound hereby, the Parties hereby agree as follows:
A. Recitals. The recitals above are true and correct and are incorporated herein by this
reference.
B. _Condition 31. Subject to the terns and conditions hereof, Condition 31 shall be satisfied
by payment to the City, prior to the issuance of building permits, as follows:
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a) TR/mm-1 Broad & South Improvements: $51,557.31
b) TR/mm-2 Broad & Capitolio Improvements: New Heritage shall pay the
Citywide traffic impact fee at the rate in effect at the time of building permit
issuance.
c) TR/mm-4 Orcutt Road/Laurel Lane Improvements: $10,746.75
d) TWmm-4, TR/mm-5 Orcutt Road Improvements: $256,290
C. Dismissal of Appeal. New Heritage hereby dismisses its appeal of the approval of the
Twin Creeks project.
D. New Heritage hereby, on behalf of itself and its partners, successors -in -interest and
assigns, irrevocably and unconditionally release and discharge the City from any and all lawsuits,
claims, actions, demands or other legal responsibilities of any kind regarding City's imposition
of the Condition. New Heritage expressly acknowledges that this Release includes any and all
claims that Plaintiffs asserted or could have asserted based upon or related to the Condition.
E. Release of Unknown Claims. New Heritage hereby waives any and all rights or
benefits that any of them may have under Section 1542 of the Civil Code of the State of California,
which provides:
"A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDI"fOR
DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF
EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE
MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.`
New Heritage acknowledges that it understands the effects of this waiver pursuant to Civil Code
Section 1542, and that it is represented and has been advised of this release by its counsel.
F. Miscellaneous
The Parties represent and warrant that they understand that they have the right to
be represented by counsel and expressly acknowledge that they have had the
opportunity to review this Agreement with their chosen counsel. The Parties
represent that they fully understand the terns of this Agreement and agree to be
bound by its contents. The Parties further represent that they have full authority to
enter this Agreement and do so of their own accord.
2. In any action or proceeding to enforce or interpret the terms of this Agreement or
otherwise arising out of the Agreement, the prevailing party shall be entitled to
recover reasonable attorney's fees.
3. This Agreement constitutes the entire agreement between the Parties with regard to
the subject matter set forth herein.
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4. It is expressly understood that this Agreement is in full accord and satisfaction of
disputed claims, and this Agreement will not be deemed an admission of liability or
responsibility of either Party hereto for any purpose.
This Agreement may be executed in multiple counterparts, each of which shall be
deemed an original, and all of which shall constitute one document to be effective as
of the Effective Date. Signatures that have been transmitted by facsimile or electronic
mail shall be deemed to be original signatures for the purposes of this Agreement.
Photocopies of this Agreement shall have the same effect as the original and may be
used in lieu of the original for any purpose.
[Signatures on following page.]
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IN WITNESS WHEREOF, the Parties have executed this Agreement as of the last date indicated
below.
New Heritage Family Limited Partnership City of San Luis Obispo
01
Joseph Collins, encral Partner 1-leidi H non, May r
Send all notices herein to: Attest:
Joseph Collins
New Heritage Family Limited Partnership
3 Ocean Bluff
Newport Coast, CA 92657
With a copy to:
Timothy J. Carmel
Carmel & Naccasha, LLP
1410 Marsh Street
San Luis Obispo, CA 93401
Teresa Purrington, City Clcrk
Send all notices herein to:
City Attorney
990 Palm Street
San Luis Obispo, CA 93401
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