HomeMy WebLinkAbout5M - Settlement w/Vetters
MEETING DATE:
AGENDA #:
PREPARED BY:
AGENDA ITEM:
DISCUSSION:
ISSUES:
FINANCIAL
IMPACT:
4646 Dakota Street S.E.
Prior Lake, MN 55372-1714
CITY COUNCIL AGENDA REPORT
MAY 7,2007
5M
STEVE ALBRECHT, DIRECTOR OF PUBLIC WORKS
CONSIDER APPROVAL OF A RESOLUTION AUTHORIZING EXECUTION OF A
SETTLEMENT AGREEMENT FOR THE VETTER LAWSUIT
Introduction
The purpose of this agenda item is to approve execution of a settlement
agreement for the Vetter lawsuit.
Historv
In fall of 2001 a fence was placed by the Vetter's in the City's drainage and utility
easement over the top of the existing forcemain. On August 29, 2001 a letter from
the City Attorney requesting the Vetter's cease and desist in the construction of
this fence was issued.
The fence and corresponding landscaping is in the middle of the City's 15 foot
drainage and utility easement which is needed to access the existing 150th Street
Lift Station. Currently the fence and landscaping prohibit access to the lift station.
The City currently accesses the lift station across a neighboring property utilizing
verbal permission from the owner.
The City has worked for nearly six years to reach an acceptable solution to the
situation. On April 6, 2007 the City and the Vetter's mediated a settlement
regarding the fence and access to the lift station. The results of the mediation
were that the Vetter's would grant the City an Irrevocable Driveway Access
License to maintain the lift station and City utilities. This license also stipulates
that upon sale of the Vetter's property the fence and landscaping must be
removed at the Vetter's cost. This agreement also clearly identifies a process for
lift station maintenance and notification of the Vetter's.
Current Circumstances
The agreement has been reviewed and recommended for approval by the City
Attorney. Additionally the Vetter's have modified the existing fence to ensure
compliance with City Codes. The Vetter's have submitted an executed copy of the
agreement to the City.
The fence will remain in place until sale of the Vetter property. However the
license agreement will provide the City with better access to the manhole than the
existing 15 foot easement. Additionally the Vetter Driveway provides the City with
a reliable emergency access.
Authorization to discontinue litigation will result in no further costs to the City.
www.cityofpriorlake.com
R:\CouncillAgenda Reports\2007\0507 07\Vettera~~ 952.447.9800 / Fax 952.447.4245
ALTERNATIVES: The alternatives are as follows:
1. Approve a resolution authorizing the City Manager to execute the Settlement
Agreement with the Vetters, Court File No. 70-CV-06-17439.
2. Deny this item for a specific reason and provide Staff with direction.
3. Table this item until some date in the future.
RECOMMENDED Alternative 1
MOTION:
nager
R:\CouncillAgenda Reportsl2007\05 07 07\Vetter agenda.doc
RESOLUTION 07-xx
A RESOLUTION AUTHORIZING EXECUTION OF A SETTELEMENT AGREEMENT FOR THE
VETTER LAWSUIT
COURT FILE NO. 70-CV-06-17439
WHEREAS,
WHEREAS,
WHEREAS,
WHEREAS,
WHEREAS,
WHEREAS,
Motion By: Second By:
In 2001, the Vetters installed a fence and landscaping on their property at 5780 150th
Street within the City's drainage and utility easement; and
On August 29, 2007 the City Attorney directed the Vetters to cease and desist
construction of the fence; and
The fence was constructed despite the City's objection and placement of this fence
restricted the City's ability to access and maintain the 150th Street lift station; and
The City of Prior Lake commenced legal action against the Vetters to have the fence
and landscaping removed; and
On April 6, 2007, the City and Vetters agreed on a mediated settlement; and
The Vetters have granted the City an Irrevocable Driveway Access License to access
and maintain the lift station.
NOW THEREFORE, BE IT HEREBY RESOLVED BY THE CITY COUNCIL OF PRIOR LAKE,
MINNESOTA as follows:
1. The recitals set forth above are incorporated herein.
2. The City Manager is authorized to execute the Settlement Agreement with the Vetters
3. The City Attorney is directed to discontinue litigation against the Vetters related to Court File No.
70-CV-06-17439.
PASSED AND ADOPTED THIS 7th DAY OF MAY 2007.
YES
NO
Haugen Haugen
Erickson Erickson
Hedberg Hedberg
LeMair LeMair
Millar Millar
Frank Boyles, City Manager
R:\Council\Agenda Reports\2007\05 07 07\Vetter Resolution.doc
www.cityofpriorlake.com
Phone 952.447.9800 / Fax 952.447.4245
03- I I
0)
halleland lewis nilan
sipkins & johnson PA
Attorneys at Law / P.A.
600 Pillsbury Center South
220 South Sixth Street
MinneaporlS, MN 55402-4501
Office: 612.338.1838 Fax: 612.338.7858
www.halleland.com
Suesan Leli Pace
Direct Dial: 612-573.2902
Emall: space@halleland.com
August 29, 2001
Ralph and Elizabeth Vetter
5780 150th Street Southeast
Prior Lake, MN 55372
RE: Cease and Desist
Dear Mr. And Mrs. Vetter:
I understand that you may be constructing a cement patio within the City's Perpetual
Easement. To follow-up Mr. Osmundson's letter to you dated August 27,2001, no fence or
patio may be placed or constructed in the Perpetual Easement. If either a fence or patio has
been placed in the Perpetual Easement, it must be removed.
Enclosed is a copy of the language of the Perpetual Easement.
Very truly yours,
S- W/.UV'I PltU: { ~
Suesan Lea Pace
City Attorney
/tag
Enclosure
cc: Frank Boyles, City Manager
'\Bud-9smtlnc:lson~ Public Works Director
DN: 126392
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STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF SCOTT
FIRST JUDICIAL DISTRICT
City of Prior Lake,
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Court File No. 70-CV-06-14739
Plaintiff,
v.
SETTLEMENT AGREEMENT
AND RELEASE
Ralph and Elizabeth Vetter,
Defendants.
This Settlement Agreement and Release (the "Agreement") is made this 7 day of
May, 2007, by and between Plaintiff City of Prior Lake and Defendants Ralph and Elizabeth
Vetter.
DEFINITIONS
1.
As used herein, "City" shall mean the City of Prior Lake and all of is attorneys, assigns,
agents, employees, subcontractors, contractors and representatives.
2. As used herein, "Vetters" shall mean Ralph and Elizabeth Vetter.
3. As used herein, "Easement" shall mean that certain easement recorded with the Scott
County Registrar of Titles on September 11, 1974 as Document No. 13031.
RECITALS
WHEREAS, the Vetters own the real property located at 5780 150th Street, S.E., Prior
Lake, Minnesota, in Scott County, Minnesota legally described on Exhibit 1 of the attached
License;
WHEREAS, the City commenced the above-entitled action against the Vetters in June
. 2006 (the "Litigation") to enforce a utility easement located on the Vetters' property;
3757877.3
WHEREAS, the City alleged that the Vetters violated the Easement in a number of ways .
by constructing a fence within the Easement and constructing a retaining wall which restricts the
City's use of the Easement;
WHEREAS, the Vetters filed an Answer denying the allegations contained in the City~s
Complaint and asserted a Counterclaim against the City for trespass;
WHEREAS, the City and the Vetters have evaluated the merits of the case after the
commencement of the Litigation; and
WHEREAS, the City and the Vetters have determined independently that it is desirable
and beneficial for each of them to settle, compromise, and resolve all claims each may have
against each other.
NOW, THEREFORE, for good and valuable consideration, the receipt and sufficiency of
which is hereby acknowledged, the City and the Vetters agree as follows: .
AGREEMENT AND RELEASE
1. The Vetters shall grant the City an Irrevocable Driveway Access License, which is
attached hereto as Exhibit A and incorporated by reference. The Irrevocable Driveway
Access License shall not be recorded by either party. The Vetters shall also relocate out
of the easement the two small arborvitae trees and hydrangea bushes located in the
east/west utility easement by August 31, 2007. The Vetters further agree not to place any
additional objects or structures, including, but not limited to, plants, trees or other
vegetation, either within the City's easement or in such a way that they restrict the City's
access to and use of its existing easement.
In exchange for the Vetters granting the Irrevocable Driveway Access License, and other
good and valuable consideration, the receipt and sufficiency which is hereby expressly
2.
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acknowledged, the City agrees to release and forever discharge the Vetters from any and
all claims that were raised or could have been raised with respect to the subject matter of
the Litigation. Nothing in this Agreement shall be construed in such a way as to limit
either the scope of the City's easement or the City's ability to enforce its laws,
ordinances, zoning and building codes, or prevent future encroachments on its easements.
Nor does it prevent the City from maintaining, repairing or replacing the utility lines that
run under the easement, should the need arise. The City expressly acknowledges and
agrees that so long as the Vetters are in compliance with the terms of this Settlement
Agreement and Release and Irrevocable License the City shall not take any action to
enforce its laws, ordinances, zoning and building codes, based on any allegation that the
Vetters use of the Easement Area, as allowed by the Settlement Agreement and Release
and Irrevocable License, violates any of the City's laws or regulations.
In exchange for the City's release set forth in Paragraph 2, and other good and valuable
consideration, the receipt and sufficiency which is hereby expressly acknowledged, the
Vetters agree to release and forever discharge the City from any and all claims that were
raised or could have been raised with respect to the subject matter of this Litigation.
Dismissal with Pre1udice. Upon execution of tlus Agreement and the Irrevocable
Driveway Access License, the parties, through counsel, shall file a Stipulation and Order
for Dismissal with Prejudice with the Scott County District Court.
MISCELLANEOUS PROVISIONS
Entire Agreement. This Agreement contains the entire agreement between the parties.
No statements, promises or inducements made by any party or any agent of any party that
are not contained in this Agreement shall be valid or binding. This Agreement may not
3
be enlarged, modified or altered, except in writing signed by all parties hereto expressly .
referencing it.
6. Legal Counsel. Each of the undersigned parties acknowledge and represents that the
party is represented by legal counsel in connection with the consideration and execution
of this Agreement. Each undersigned party represents and declares that in executing this
Agreement, the party has relied solely upon the party's own judgment, belief and
knowledge, and the advice and recommendation of the party's own independently
selected legal counsel concerning the nature, extent and duration of the party's rights and
claims, and that the party has not been influenced to any extent whatsoever in executing
this Agreement by any representations or statements not expressly contained or referred
to herein. Each party shall be responsible for the cost of their own attorney.
7. Non-waiver. No delay or failure by any of the parties to exercise any right under this .
Agreement and no partial single exercise of any right shall constitute a waiver of that or
any other right, unless otherwise expressly provided herein.
8. Binding Effect. This Agreement, when effective, shall constitute a legal, valid, and
binding obligation of the parties, enforceable in accordance with its terms.
9. Interpretation. This Agreement shall not be construed against the party preparing it, but
shall be construed as if all parties, and each of them, jointly prepared it, and any
uncertainty or ambiguity shall not be interpreted against anyone party.
10. Counterparts. This Agreement may be signed in counterparts.
11. Duty to Cooperate. All parties agree to cooperate fully and to execute any and all
supplementary documents and to take all additional actions that may be necessary or
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3757877.3
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appropriate to give full force to the basic terms and intent of this Agreement and which
are not inconsistent with its terms.
12. Invalidity. Should any of the provisions of this Agreement be rendered invalid by a court
of competent jurisdiction) it is agreed that this shall not in any way or manner affect the
enforceability of the other provisions of this Agreement which shall remain in full force
and effect.
13. Choice of Law. This Agreement shall be governed by) and inspected in accordance with)
the laws of the State of Minnesota, not including its choice-of-law rules. It is the express
intent of the parties that this Agreement be binding and enforceable under the principles
of law applicable to contract and that the Agreement itself may be used as evidence in
subsequent proceeding in which any party alleges a breach of this Agreement.
. 14. Action by Prior Lake City Council. Although the Parties agree that this Agreement does
not become effective until it is approved by a vote of the Prior Lake City Council, the
Parties agree to be bound by this Agreement unless the Agreement is not approved by the
Prior Lake City Council at its May 7, 2007 meeting. This Agreement shall be null and
void if the Prior Lake City Council does not approve the Agreement at its May 7) 2007)
meeting and if all parties do not sign the Agreement on May 7) 2007.
15. Dispute Resolution. Any disputes regarding the terms of this Settlement Agreement and
Release and the Irrevocable License shall be submitted to Retired Judge Roland Faricy
or) in the event that Judge Roland Faricy is unavailable) a qualified neutral designated by
agreement of both parties) by letter and without oral argument and Judge Faricy)s
decision shall be final) without right of appeal therefrom. The parties agree that Judge
. Faricy will bill the parties equally for his time at his current hourly rate for mediations.
3757877.3
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IN WITNESS WHEREOF, the undersigned parties have executed this Agreement to be .
effective as of the date first set forth above.
(The remainder of this page was intentionally left blank.)
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Dated: <-ff/atr Z..ztJb?
I
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~~L~
piiZabeth Vetter
!/it;-
Subscribed and sworn to before me
n~
this L day of May, 2007.
~~)v~
Notary Public
Dated: iJ 1 }O'l
Subscribed and sworn to before me
J1.1
this V] day of May, 2007.
~~~ A!\/
Notary Public ( ()
MARTHA ANNE WAl2
NOTARY PUBLIC. MINNESOTA
My Commission Expires Jan. 31, 2010
APPROVED AS TO FORM:
~ Jf.?U4- ~;lc7
Marc D. SlTIlp- n, Esq. (#183301)
Timothy M. Kelley, Esq. (#303847)
LEONARD, STREET AND DEINARD,
Professional Association
150 South Fifth Street, Suite 2300
Minneapolis, MN 55402
Attorneys for Defendants
(The remainder of this page was intentionally left blank.)
3757877.3
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Dated:
By:
CITY OF PRIOR LAKE
Jack C. Haugen
Its: Mayor
Subscribed and sworn to before me
this _ day of May, 2007.
Notary Public
APPROVED AS TO FORM:
Dated:
By:
Frank Boyles
Its: City Manager
Subscribed and sworn to before me
this day of May, 2007.
Notary Public
APPROVED AS TO FORM:
Suesan Lea Pace (#0199345)
Michael E. Burns (#314869)
HALLELAND LEWIS NILAN & JOHNSON, P.A.
600 U.S. Bank Plaza South
220 South Sixth Street
Minneapolis, MN 55402
Attorneys for Plaintiff
(The remainder of this page was intentionally left blank.)
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EXHIBIT A
37578773
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IRREVOCABLE DRIVEWAY ACCESS LICENSE
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Ralph and Elizabeth Vetter ("Grantors") hereby grant an irrevocable driveway access
license (the "License") in favor of t~y of Prior Lake, a Minnesota [municipal corporation]
("Grantee") as of the 7 day of /21' 2007 on the terms set forth herein.
RECITALS
A. Grantors own the real property located at 5780 1501h Street, S.E., Prior Lake,
Minnesota, in Scott County, Minnesota legally described on Exhibit 1 attached hereto (the
"Grantors' Property").
B. Grantors hereby agree to permit Grantee to access the Easement Area, as defined
in Paragraph 1 below, through the existing driveway located on a portion of the Grantors'
Property as shown on Exhibit 2 attached hereto (the "License Area"), on the terms forth in this
License.
NOW, THEREFORE, in consideration of the mutual promises set forth herein and other
good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged,
the parties hereby agree as follows:
1. Grant of License. Subject to the terms contained herein, Grantors hereby grant to .
Grantee the right and license to enter onto and access the existing paved driveway in the License
Area (the "Driveway") in order for Grantee to access that certain Perpetual Easement for
Sanitary Sewer, Watermain, Storm Drains and Utility Purposes located over the Easterly 7.50
feet of the Southerly 357.60 feet of the Grantors' Property (the "Easement Area"). This access
shall include access across the yard from the end of the driveway to the lift station and shall not
extend more than twenty feet away from the fence currently located within the Easement Area.
The Grantee shall make reasonable efforts to minimize its use of the yard from the end of the
driveway to the lift station. During the term of this License, Grantors shall not substantially alter
the size and location of the Driveway.
2. No License Fee. The parties agree that Grantee shall have no obligation to pay to
Grantors any fee in connection with this License.
3. Term. The Term of this License shall commence on the date it is executed by
both parties and shall automatically terminate on the earliest of the following: 1) the date the
Grantors sell or covey their interest in the Grantors' Property; 2) the date that the Grantors cease
to reside on the Grantors property; 3) the date that the Grantors permanently remove the fence
that is currently located on the easterly portion of the Grantors' Property, the trees located within
the Easement Area at the south end of the fence along the driveway, the retaining wall and any
other item obstructing the Easement Area (the "Grantors' Personal Property").
4. The Grantors' Removal of the Grantors' Personal Property. Before marketing the .
Property for sale or before any interest in the Property is conveyed or sold, Grantors
3757877.3
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acknowledge and agree that they shall remove the Grantors' Personal Property from the
Easement Area. In the event the Grantors remove the Grantors' Personal Property, the Grantors
shall provide the Grantee with written notice of such removal and a copy of any then existing
listing agreement for the Property, which will document that those items were removed prior to
the date the Grantors listed their Property for sale. Upon delivery of the written notice required
by this Paragraph to the Grantee, the License shall terminate and the Grantee's right to access the
Property shall be governed by the Easement recorded with the Scott County Registrar of Titles
on September 11, 1974 as Document No. 13031.
In the event that Grantors fail to remove the above-referenced fence before the property is
conveyed or sold, Grantee may remove the Grantors' Personal Property from the Easement Area
and Grantors shall reimburse Grantee for the cost of its removal. Grantor shall indemnify and
hold harmless Grantee for any claim or action involving the successor owner of Grantor's
Property related to Grantee's removal of any item of the Grantors' Personal Property described
herein from the Easement Area.
5. Indemnification. Grantee shall repair any damage to Grantors' Personal Property
or improvements located outside of the utility easement damaged by or through Grantee's use of
the License and Easement Area, except that Grantee Shall not be responsible for repairs to the
driveway for damage caused by normal wear. The Grantors shall indemnify, defend, and hold
the Grantee harmless for damage done to personal property and improvements located within the
Easement Area, or restricting its access to the Easement Area, except that the Grantee will
replace any topsoil and sod destroyed or materially damaged by or through Grantee's use of the
easement.
6. Driveway Restrictions. The Grantee's access over the Driveway and the yard
shall be limited to a one-ton pickup truck sized vehicle, a small rubber tired backhoe or a small
bobcat, and shall not include any heavy equipment not described herein, except that Grantee may
also operate a vactor truck as long as the vactor truck's access is limited to the driveway only. In
the case of routine maintenance or in the event that access over the Driveway and yard are
restricted by actions of Grantors, their invitees, or their guests (e.g. parked vehicles, landscaping,
etc.), Grantee shall communicate with Grantors to mutually determine the least disruptive and
least destructive means and time to access the Easement Area. The terms of this paragraph do
not allow Grantors to deny Grantee access to conduct necessary maintenance.
The Grantors have also informed the Grantee that they are hosting a wedding at their
Property in July 2007. In the case of routine maintenance, the Grantors and the Grantee
acknowledge that such work may be delayed at the request of the Grantors until after the
wedding in July 2007. Prior to conducting any routine maintenance in the Spring or Summer of
2007, the Grantee shall provide Grantors with reasonable, written advance notice of the
Grantee's proposed schedule to conduct routine maintenance. At the request of the Grantors, the
Grantee will agree to schedule the routine maintenance after the wedding.
7. Emergency Access. In the case of an emergency (e.g. sewage back-up, ruptured
pipes), and in the event that access over the Driveway and yard are restricted by actions of
Grantors, their invitees, or their guests (e.g. parked vehicles, landscaping, etc.), Grantors shall
immediately remove the obstruction or Grantee may remove the obstruction at Grantors expense
if Grantors fail to do so. If Grantee removes all the Grantors' Personal Property from the
3757877.3
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Easement Area, the Grantee's right to access the Property shall be governed by the Easement .
recorded with the Scott County Registrar of Titles on September 11, 1974 as Document No.
13031. Within a reasonable period of time after removal of any obstructions pursuant to this
paragraph, Grantee shall provide Grantors a written certification as to the nature of the
emergency and the Grantee's reasons for making the emergency repairs. Such written
certification shall be signed by the City Engineer or an individual, who is a licensed engineer and
was employed or hired by the Grantee.
In the event that Grantee or the Grantors remove the fence, Grantors shall also be
permitted to restore the fence, in substantially the same location and size, at their own expense
after such removal and the License shall continue.
Subscribed and sworn to before me
n~("
this lday of May, 2007.
.
Subscribed and sworn to before me
i1~
r. ~day of May, 2007.
~9\4
Notary Public
MARTHA ANNE WAll
NOTARY PUBLIC - MINNESOTA
My Commission Expires Jan. 31, 2010
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3757877.3
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GRANTEE:
City of Prior Lake
Dated:
Subscribed and sworn to before me
this _ day of May, 2007.
Notary Public
3757877.3
By:
Frank Boyles
Its: City Manager
13
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EXHIBIT 1
Lots 22 & 23, First Addition to Eastwood, Scott County, Minnesota, according to the recorded
plat thereof. (PID No. 25-047021-0).
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