HomeMy WebLinkAboutRDA TAX SETTLEMENT 10-07-91RDA N0. 5
10-7-91
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TE: September 24, 19 91_x.
HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL and
TO: TUSTIN REDEVELOPMENT AGENCY
FROM: CITY ATTORNEY
S`U BJECT: PENALTY TAX SETTLEMENT AGREEMENT
Our office has received the final Settlement Agreement and
Mutual Release from the County of Orange which reflects the
previous negotiated settlement of Tustin's and Tustin Redevelopment
Agency's lawsuit against the Countyfor a share of the property tax
penalties. As you may recall, our office filed a lawsuit on behalf
of Tustin, the Tustin Redevelopment Agency and numerous other
public entities against the County of Orange for payment of
property tax penalty funds withheld by the County.
The County of Orange collects the property tax penalties from
property owners who are delinquent in paying property taxes.
Beginning in 1985-86, the Orange County. Auditor -Controller
impounded the tax penalty monies, refusing to distribute them to
the various local public agencies' general funds. Following such
impound, various lawsuits wer.e,fi.le-d against the County on behalf
of the local public agencies within the County -demanding that the
property tax penalties be distributed.
The lawsuit brought by the City of Anaheim was the first to be
heard at the trial level and Anaheim prevailed. The County of
Orange filed an appeal. Meanwhile, the County lobbied the State
Legislature to enact AB 2372 which provided that the County was
entitled to keep all property tax penalties. In addition, the
legislation provided that it was to be retroactive as to those
counties which had impounded the tax penalty monies prior to the
effective date of the legislation. This legislation was passed,
resulting in a validation of the County of Orange's retention of
the property tax penalties from the year 1985-86, to the present.
DAD:cj ♦ :S\1506A
Inter -Com
Page Two
September 24, 1991
The other local public agencies proceeded with their lawsuits
on the theory that the legislation could not be retroactive.
However, it was our belief, and the belief of the attorneys
representing other agencies, that our chances of prevailing were
slight.
During settlement negotiations, the County offered to pay all
local agencies 15% of the property tax penalties. Acting in
conjunction, the local agencies countered at 25% and all parties
finally settled at 22%. The Settlement Agreement and Mutual
Release reflect these negotiations accurately. They provide that
Tustin and Tustin Redevelopment Agency will receive 22% of all
impounded tax penalties for the years 1985-86, 1986-87, 1987-88 and
1988-89. The amount of money to be received by Tustin is 22% of
$74,247, or $16,334. The Tustin Redevelopment Agency is to receive
22% of $54,428, or $11,974. Please place the Agreements on the
agendas for the next available meetings of the City and Agency. We
recommend that the Agreements be approved and signed and that the
signature pages be returned to us for forwarding to the County.
JJG. DAVID A. De
CITY ATTORNEY DEPUTY CITY A
DAD:cj ♦ :S\1506A
cc: W. Huston
R. Nault
DAD:cj ♦ :S\1506A
1 SETTLEMENT AGREEMENT
3 THIS AGREEMENT is entered into by and between the Orange County
4
cities, redevelopment agencies, and special districts (hereinafter
S "Cities, Agencies, and Districts") named'in Exhibit A hereto, and the
6 County of Orange as follows:
7
WHEREAS, certain disputes have arisen between the Cities,
8 Agencies, and Districts and the County of Orange regarding the allo-
t
cation of delinquent property tax penalties collected by the Orange
10 County Tax Collector;
Il WHEREAS, the Orange County Auditor-Controller has impounded � P d the
12
disputed delinquent tax penalties for tax years 1985-86, 1986-87,
13 1987-88, and 1988-89;
U WHEREAS, Cities, Agencies, and Districts have filed in. the Orange
w
000 County Superior Court twenty separate actions seeking recovery of the
V
> 16 disputed delinquent tax
i` P q penalties. The title and case number of each
°° 1' case is listed in Exhibit B hereto, and incorporated herein by
18 reference;
19 WHEREAS the
parties wish to resolve all disputes as to the
20 allocation of the tax delinquent q ,penalties in question, terminate the
21 actions listed in Exhibit B and
provide the allocation and
" distribution of the funds presently impounded;
23 NOW, THEREFORE, it is hereby agreed as follows:
24 1. The delinquent property tax
penalties attributable to
25 property taxes allocated to each City, Agency, or District an '
-. d which
26 were impounded by the Orange County Auditor for taxear 1985-8
w
y 6,
1986-87, 1987-88 and 1988-89 shall be divided, distributed or
28 `
disbursed at a ratio of seventy-eight percent (781) to the County of
6118/9121.
1 Orange and twenty-two percent (22♦) to the Cities, Agencies, and
Districts, and specifically in the amounts and to the Cities,
Agencies, and Districts as named and listed in Exhibit A. No interest
4 shall.be payable to the Cities, Agencies, or Districts by or on
S account of this Settlement Agreement.
6 2. Upon receipt of the amounts listed in Exhibit A, the Cities,
Agencies, and Districts shall cause to be filed with the Orange County
8 Superior Court (or the Fourth District Court of Appeal in Community
9 Redevelopment Agency of the Cit of Santa Ana et al. v. V. A. Heim
10 e_., case No. G-010669 (OCSC No. 55-09-70)).a Request for Dismissal
1
11. by which full dismissal with prejudice of each and every action
I
12 currently filed and pending by the Cities, Agencies, and Districts and
13 against the County shall be obtained.
14 3. The parties will execute concurrently with this Agreement a
J
00 mutual general release in the form attached hereto as Exhibit "C."
Zi 16 4. Each of the parties to this Agreement represents and warrants
- 1
00 to the other that M each of them has the full power, capacity and
18 authority to enter into this Agreement and (ii) no promise or induce -
19 ment has been offered or made for this Agreement except as set forth
20
herein. The representations and warranties made herein shall survive
21 the execution and delivery of this Agreement and shall be binding upon
22 the respective successors and assigns of the County, y, and the Cities,
23 Agencies, and Districts.
24 5. The parties hereto, and each of them, represent and declare
25 that in executing this Agreement they relied solely upon their own
26 judgment, belief and knowledge, and the advice and recommendations of
N
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their own independently selected counsel, concerning the nature, ,
i
28 extent and duration of their
rights and claims, and that they have not
M/200 2,
8/91
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been influenced to any extent whatsoever in executing the same by any
representations or statements Oovering any matter made by any other
party hereto or any person representing any of such other parties
hereto.
6. This Agreement and the attached Exhibits constitute the
entire agreement between the parties pertaining to the subject matter
-hereof, and the final, complete and exclusive expression of the terms
and conditions of their agreement. Any and all prior agreements,
representations, negotiations and understandings made by the parties,
oral or written, express or implied, are hereby superseded and merged
herein.
7. This Agreement may be executed in any number of counterparts,
each of which shall be an original, but all of which shall constitute
one and the same instrument.
8. The parties hereto, and each of them, further represent and
declare that they have carefully read this Agreement and know the
contents thereof and that they signed the same freely and voluntarily.
IN WITNESS WHEREOF, the parties hereto have executed this Agree-
ment as of the day and year dated below.
Dated: , 1991.
.
ep3/200
6/18/91
COUNTY OF ORANGE
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Approved As To Form:
Attorney for CAPISTRANO BAY.
PARR AND RECREATION DISTRICT
and LYNN MUIR
Approved As To Form:
Attorney for CITY OF COSTA
MESA and REDEVELOPMENT AGENCY
OF THE CITY OF COSTA MESA
Approved As To Form:
Attorney for CITY OF CYPRESS
and CITY OF CYPRESS RECREATION
AND PARR DISTRICT, THE CYPRESS
REDEVELOPMENT AGENCY and
MARGARET ARNOLDI MAYOR
ep3/600
CAPISTRANO BAY PARR AND RECREATION
DISTRICT
By
Its
Lynn Muir
CITY OF COSTA MESA
By
Its
REDEVELOPMENT AGENCY OF THE
CITY OF COSTA MESA
By
Its
CITY OF CYPRESS
By
Its
CITY OF CYPRESS RECREATION AND
PARK DISTRICT
By
THE CYPRESS REDEVELOPMENT AGENCY
By
Its
Margaret Arnold
CITY OF FOUNTAIN VALLEY
By
Its
George Scott
CITY OF FULLERTON
By
Its
FULLERTON REDEVELOPMENT AGENCY
By
Its
ORANGE COUNTY WATER DISTRICT
By
Its
CITY OF IRVINE
By
Its
CITY OF LAGUNA BEACH
By
Its
--
1
Approved As To Form:
2
.3
Attorney for CITY OF FOUNTAIN
VALLEY and GEORGE SCOTT
4
5
6
7
Approved As To Form:
8
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Attorney for CITY OF
FULLERTON, FULLERTON REDEVELOP -
10
MENT AGENCY, ORANGE COUNTY
WATER DISTRICT, CITY OF IRVINE,
11
CITY OF LAGUNA BEACH, CITY OF
SAN CLEMENTE REDEVELOPMENT
12
AGENCY, CITY OF YORBA LINDA,
YORBA LINDA REDEVELOPMENT AGENCY,
13
YORBA LINDA LIBRARY DISTRICT,
FOUNTAIN VALLEY AGENCY FOR
14
COMMUNITY DEVELOPMENT, CITY OF
LA PALMA, LA PALMA REDEVELOPMENT
0'3
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AGENCY, SANTIAGO COUNTY WATER
W0,0
DISTRICT, TRI -CITIES MUNICIPAL
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WATER DISTRICT, and ROSSMOOR
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COMMUNITY SERVICE DISTRICT
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CITY OF FOUNTAIN VALLEY
By
Its
George Scott
CITY OF FULLERTON
By
Its
FULLERTON REDEVELOPMENT AGENCY
By
Its
ORANGE COUNTY WATER DISTRICT
By
Its
CITY OF IRVINE
By
Its
CITY OF LAGUNA BEACH
By
Its
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CITY OF SAN CLEMENTE
By
Its
SAN CLEMENTE REDEVELOPMENT AGENCY
By
Its
CITY OF YORBA LINDA
By
Its
YORBA LINDA REDEVELOPMENT AGENCY
By
Its
YORBA LINDA LIBRARY DISTRICT
By
Its
FOUNTAIN VALLEY AGENCY FOR
COMMUNITY DEVELOPMENT
By
Its
CITY OF LA PALMA
By
Its
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LA PALMA REDEVELOMENT AGENCY
By
Its
SANTIAGO COUNTY WATER DISTRICT
By
Its
TRI -CITIES MUNICIPAL WATER DISTRICT
By
Its
ROSSMOOR COMMUNITY SERVICE DISTRICT
By
.Its
Approved As To Form:
CITY OF GARDEN GROVE
Attorney for CITY OF GARDEN
GROVE, GARDEN GROVE AGENCY By
Its
FOR COMMUNITY DEVELOPMENT
and J. TILMAN WILLIAMS
GARDEN GROVE AGENCY FOR COMMUNITY
DEVELOPMENT
By
Its
J. Tilman Williams
ep3/600
2
3
4
5
6
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11
12
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Approved As To Form:
Attorney for GARDEN GROVE
SANITARY DISTRICT and
ROBERT MAIN
Approved As To Form.-
Attorney(s)
orm:
Attorneys) for CITY OF
HUNTINGTON BEACH, HUNTINGTON
BEACH REDEVELOPMENT AGENCY
and JOHN ERSKINE
Approved As To Form:
Attorney for LAGUNA BEACH
COUNTY WATER DISTRICT
Approved As To Form:
Attorney for CITY OF LA HABRA,
REDEVELOPMENT AGENCY OF
LA HABRA and JAMES A. FLORA
ep3/600
GARDEN GROVE SANITARY DISTRICT
By
Its
Robert Main
CITY OF HUNtINGTON BEACH
By
Its
HUNTINGTON BEACH REDEVELOPMENT
AGENCY
By
Its
John Erskine
LAGUNA BEACH COUNTY WATER DISTRICT
By_
Its
CITY OF LA HABRA
By_
Its
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Approved As To Form:
Attorneys for CITY OF
LOS ALAMITOS and
CHARLES E. SYLVIA, MAYOR
Approved As To Form:
Attorneys for CITY OF MISSION
VIEJO, independently and as
Successor -in -Interest to the
Mission Viejo Community
Services District and
NORMAN P. MURRAY, MAYOR
.
ep3/600
REDEVELOPMENT AGENCY OF LA HABRA
By
Its
James A. Flora
CITY OF LOS ALAMITOS
By_
Its
Charles E. Sylvia
CITY OF MISSION VIEJO,
- independently, and as Successor -
In -Interest to the Mission Viejo
Community Services District
By_
Its
Norman P. Murray
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Approved As To Forth:
CITY OF NEWPORT BEACH
Attorney for CITY OF NEWPORT
BEACH and JOHN C. COS, JR. Its
John C. Cox, Jr.
Approved As To Form: CITY OF PLACENTIA
By
Attorney for CITY OF
PLACENTIA, PLACENTIA
Its
REDEVELOPMENT AGENCY
and JOHN 0. TYNES
PLACENTIA REDEVELOPMENT AGENCY
By
Its
John 0. Tynes
Approved As To Form:
COUNTY SANITATION DISTRICT NO. 1
Attorney for COUNTY
By
SANITATION DISTRICT NOS.
1, 2, 3, 5, 6, 7, and 11 of
Its
ORANGE COUNTY, CALIFORNIA;
CITY OF TUSTIN, TUSTIN COMMUNITY
REDEVELOPMENT AGENCY; MIDWAY
COUNTY SANTIATION DISTRICT NO. 2
CITY SANITARY DISTRICT; LOS
ALAMITOS COUNTY WATER DISTRICT;
SOUTH COAST WATER DISTRICT.and
By
IMPROVEMENT DISTRICT NO. 1 OF
SOUTH COAST WATER DISTRICT
Its
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Approved As To Form:
Attorney for CITY OF SAN JUAN-
CAPISTRANO, CITY OF SAN JUAN
CAPISTRANO COMMUNITY REDEVELOP-
MENT AGENCY, and
STEPHEN B. JULIAN
ep3/600
MIDWAY CITY SANITARY DISTRICT
By
Its
LOS ALAMITOS COUNTY WATER DISTRICT
By
Its
SOUTH COAST WATER DISTRICT
By
Its
IMPROVEMENT DISTRICT NO. 1 OF
SOUTH COAST WATER DISTRICT
1
By
Its
CITY OF SAN JUAN CAPISTRANO
By
Its
CITY OF SAN JUAN CAPISTRANO
REDEVELOPMENT AGENCY
By
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1
1
1
3
4
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6
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8
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Approved As To Form: CITY OF SANTA ANA
MENT AGENCY, MARTHA V. WIESHAUPTr
MAJOR, and PAUL VERELLEN
ep3/600
By•
Attorney for CITY OF
SANTA ANA, COMMUNITY REDEVELOP-
Its
MENT AGENCY OF THE CITY OF
SANTA ANA
COMMUNITY REDEVELOPMENT AGENCY OF
THE CITY OF SANTA ANA
By
Its
Approved As To Form:
CITY OF SEAL BEACH
Attorneys for CITY OF SEAL
By
BEACH, REDEVELOPMENT AGENCY
OF THE CITY OF SEAL BEACH
Its
REDEVELOPMENT AGENCY OF THE
CITY OF SEAL BEACH
By
Its
Approved As To Form:
CITY OF STANTON
By
Attorneys for CITY OF
STANTON, STANTON REDEVELOP-
Its
MENT AGENCY, MARTHA V. WIESHAUPTr
MAJOR, and PAUL VERELLEN
ep3/600
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Approved As To Form:
Attorney for CITY OF
WESTMINSTER, WESTMINSTER
REDEVELOPMENT AGENCY,
WESTMINSTER MUNICIPAL
LIGHTING DISTRICT and
CITY OF WESTMINSTER SPECIAL
DISTRICT AUGMENTATION
TAX FUND
ep3/600
STANTON REDEVELOPMENT AGENCY
By_
Its
Martha V. Weishaupt
Paul Verellen
CITY OF WESTMINSTER
By
Its
WESTMINSTER REDEVELOPMENT AGENCY
By
Its
WESTMINSTER MUNICIPAL LIGHTING
DISTRICT
By
Its
CITY OF WESTMINSTER SPECIAL
DISTRICT AUGMENTATION AX FUND
By
Its
EXHIBIIT A
C2TIES DISPUTED TAX Eti71I,TIES
AND COMMUNITY REDELOPMENT 1►GENCIES
Exh. A, Page 1 of 2
SETTLEMENT
PAYMENT
FUND
1
FUND NAME
TOTAL
PENALTIES
22� OF
TOTAL
PENALTIES
2
------------------------------- 34
0002 �------------------
COSTA MESA
--------- ---
0003
CRA
FULLERTON CRA
$24,83280
$5,463
0004
GARDEN'GROVE CRA
156
$17,634
0005
SANTA ANA CRA
154. 474
,
33.984
0007
S EA,L BEACH CRA
105j439
230197
0008
0009
SAN CLEMENTE CRA
LA HABRA CRA
16,314
11#063
31589
2,434
0014
CYPRESS CRA
7,512
1,653
0015
0016
FOUNTAIN*VAL CRA
HUNT BEACH CRA
1,237
851
272
1627
0019
LA PALMA CRA
30.527
2,716
0023
PLACENT CRA
13,217
908
0024
0025
SAN JUAN
RA
STANTON CRA
9,036
10,494
1,988
2,309
0026
TUSTIN CRA
17,14428
0027
SANTA ANA CRA
13, 971
0028
WESTMINSTER CRA
237,119
52,
166
0029
YORBA LINDA CRA
128882
2,834
0037
MISSION VIEJO
40,044
81810
0038
IRVINE
29.377
61463
0039
YORBA LINDA
243,863
53,650
0043
COSTA MESA
119,652
26,324
0044
CYPRESS
219,520
48,294
0045
LA PAS
62.208
13,686
0046
FOUNTAIN VALLEY
24.496
5,389
0047
FULLERTON
67,527
140856
0048
GARDEN GROVE
184.826
40,662
0049
HUNTINGTON BEACH
152.526
330556
0050
LAGUNA BEACH
429.765
94,548
0051
LA HABR,A
165.758
36,467
0052
LOS ALAMITOS
75.313
16,569
0053
NEWPORT BEACH
15,491
3,408
0056
PLACENTIA
327,656
72084
0057
SAN CLEMENTE
54.122
11,907
0058
0059
SAN JUAN CAPISTRANO
SANTA ANA
133.040
53,110
29,269
11.684
0060
SEAL BEACH
342,150
75,273
0061
STANTON
48.285
10,623
0062
TUSTIN
37,14 3
8,172
0064
WESTMINSTER
74.247
16,334
56,115
12.345
TOTAL-----------------------
$3.819.955
$840,392
Exh. A, Page 1 of 2
DISPUTED TAX PENALTIES - LITIGATING ENTITIES
22% OF
TOTAL TOTAL
FUND FUND NAME PENALTIES PENALTIES
1 2 3 4
--------------------------------- * -------------------
DISPUTED TAX PENALTIES - INDEPENDENT SPECIAL DISTRICTS
0010
CYPRESS REC/PARK
0066
MIDWAY CITY SAN
0067
GARDEN GROVE SAN
0074
TRI CITIES WATER
0080
LAGUNA BEACH WATER
0081
SOUTH COAST WATER
0086
SANTIAGO WATER
0093
LOS ALAMITOS WATER
0099/5171
ROSSMOOR CSD
5081
YORBA LINDA LIBRARY
5091
YORBA LIN LIB BONDS
5101
YORBA LIN LIB BONDS
5271
CAPD BAY PARK\REC
5521
MISSION VIEJO CSD
5881
OC WATER DISTRICT
5901
OC WATER DIST RESERVE
9021
OC SANIT NO. 1 OPERATINIG
9031
OC SANIT NO. 2 OPERATINIG
9041
OC SANIT NO. 3 OPERATINIG
9051
OC SANIT NO. 5 OPERATINIG
9061
OC SANIT NO. 6 OPERATINIG
9071
OC SANIT NO. 7 OPERATING
9091
OC SANIT NO. 11 OPERATIING
9161
OC SANIT NO. 1 BOND/INTI 51
9191
OC SANIT NO. 5 BOND/INT '51
9201
OC SANIT NO. 6 BOND/INT''51
9221
OC SANIT NO. 11 BOND/INET 151
9281
OC SANIT NO. 11 INT/SINX 158
9861
OC SANIT NO. 3 & 11 OPER SUSP
TOTAL INDEPENDENT DISTRICTS
$23,488 $5,167
59,588 13,109
17,202
3,784
15,053
31312
15,307
3,368
38,418
8,452
7,821
1,721
1, 573
'346
4,350
957
2
0
936
206
88
19
7,577
1,667
43,722
9,619
117,053
25,752
1, 741
383
61,155
131454
134,077
29,497
172,542
37,959
53,427
11,754
40,834
8,984
57,092
121560
44,290
9,744
1,337
294
482
106
247
54
258
57
991
218
8,479
11865
$929,130 $204,408
Exh. A, Page 2 of 2
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EXHIBIT B
CASE LIST
Case Name Case Number
1. Capistrano Bay Park and Recgeation District, 56 19 94
et al. v. County of Orange,+et al.
2. City of Costa Mesa v. S. E.,Lewis, et al. 56 24 88
3. City of Cypress, et*al. v. Bounty of 56 91 27
Orange, et al.
4. City of Fountain Valley, et al. v. 55 52 10
County of Orange, et al.
5. City of Fullerton, et al.'v.,County 56 08 61
of OranctO, et al.
6. City of Garden Grove, et al.;v. County_ 55 43 61
of Orange, et al.
7. Garden Grove Sanitary Distrigt, et al. 55 80 51
v. County of Orange, et al.
8. City of Huntington Beach, et}al. v. 54 79 89
County of Orange, et al.
9. Laguna Beach County Water Diptrict v. 56 14 17
County of Orange, et al.
10. City of La Habra, et al. v. bounty of
Orange, et al.
11. City of Los Alamitos, et al. v. County
of Orange, et al.
12. City of Mission Viejo, et al, v. County
of.Orange, et al.
JXM/6
1
56 05 30
56 91 28
91,19,01, ; .
1
2
3
4
5
6
7
8
9
10
11
12
13
14
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00 17
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18
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20
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22
23
24
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28
EXHIBIT B
CASTE LIST
Case Name
13. City of Newport Beach, et al. v. County
of Orange, et al.
14. City of Placentia, et al. v. �Co=nty_
Orange, et al.
15.
Case Number
55 77 68
55 83 92
56 09 06
County of Orange, et al.
16. City of San Juan Capistrano, jet al. V. 55 94 20
County of Orange, et al.
17.
Community RedeveloRLaent A en
of the.
Cit of Santa Ana et al. V.
V. A. Heim
et al.
18.
City of Seal Beach, et al. v _,
County of
County of Orange, et al.
19.
City of Stanton, et al. v. County
of
Orange, et al.
20.
City of Westminster, et al. v$
County of
Orange, et al.
•
JXM/6
2
55 09 70
G-010669
(DCA -4th)
61 13 66
56 91 29
55 65 17
1
2'
311
4
5
6
7
8
9
10
11
12
13
14
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18
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22
23
24
25
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?7
28
MUTUAL GENERAL RELEASE
1. Parties
The parties to this mutual general release (the "release")
are the COUNTY OF ORANGE, a political subdivision of the State of
California, CAPISTRANO BAY PARK AND RECREATION DISTRICT, a municipal
corporation, LYNN MUIR, Directoriof Capistrano Bay Park and Recreation
District, CITY OF COSTA MESA, a municipal corporation, REDEVELOPMENT
AGENCY OF THE CITY OF COSTA MESA, a public body, CITY OF CYPRESS, a
charter city, CITY OF CYPRESS RECIREATION AND PARK DISTRICT, an .
independent special district, CYPRESS REDEVELOPMENT AGENCY, an
independent public entity, MARGARET ARNOLD, a citizen, resident and
Mayor of the City of Cypress, CITY OF FOUNTAIN VALLEY, a municipal
corporation, GEORGE SCOTT, a citizen and"former Mayor of the City of
Fountain Valley, CITY OF FULLERTON, a public entity, FULLERTON
REDEVELOPMENT AGENCY, a public entity, ORANGE COUNTY WATER DISTRICT, a
public entity, CITY OF IRVINE, a public entity, CITY OF LAGUNA BEACH,
a public entity, CITY OF SAN CLEMENTE, a public entity, SAN CLEMENTE
REDEVELOPMENT AGENCY, a public entity, CITY OF YORBA LINDA, a public
entity, YORBA LINDA REDEVELOPMENT AGENCY, a public entity, YORBA LINDA
LIBRARY DISTRICT, a public entity;, FOUNTAIN VALLEY AGENCY FOR
COMMUNITY DEVELOPMENT, a public entity, CITY OF LA PALMA, a public
entity, LA PALMA REDEVELOPMENT AGENCY, a public entity, SANTIAGO
COUNTY WATER DISTRICT, a public entity, TRI -CITIES MUNICIPAL WATER
DISTRICT, a public entity, ROSSMOOR COMMUNITY SERVICE DISTRICT, a
public entity, CITY OF GARDEN GROVE, a municipal corporation, J.
TILMAN WILLIAMS, citizen, resident and Mayor of the City of Garden
Grove,.GARDEN GROVE AGENCY FOR COMMUNITY DEVELOPMENT, a public body,
1.
I
GARDEN GROVE SANITARY DISTRICT, a political subdivision of the State
2
of California, ROBERT MARIN, a director of, and resident in, Garden
3
Grove Sanitary District, CITY OF HUNTINGTON BEACH, a municipal
4
corporation, JOHN ERSKINE,*citiz@n, resident, and Mayor of the City of
5
Huntington Beach, HUNTINGTON BEACH REDEVELOPMENT AGENCY, a public
6
body, LAGUNA BEACH COUNTY WATER DISTRICT,- a local special district,
7
CITY OF LA HABRA, a municipal corporation, JAMES A. FLORA, citizen,
8
resident and Mayor of the City of La Habra, REDEVELOPMENT AGENCY OF LA
9
HABRA, a public body, CITY OF LOS ALAMITOS, a charter city, CHARLES E.
10
SYLVIA, citizen, resident and Mayor of the City of Los Alamitos, CITY
11
OF MISSION VIEJO, a municipal corporation and as successor in interest
12
to the Mission Viejo Community Services District, NORMAN P. MURRAY,
13
citizen, resident and Mayor*of the City of Mission Viejo, CITY OF
14
NEWPORT BEACH, a municipal corporation, JOHN C. COX, JR., citizen,
o;;
15
resident and Mayor of the City of Newport Beach, CITY OF PLACENTIA, a
W0
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16
municipal corporation, JOHN 0. TINES, citizen, resident and Mayor of
IL
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17
the City of Placentia, PLACENTIA REDEVELOPMENT AGENCY, a public body,
18
COUNTY SANITATION DISTRICT NOS. I, 2, 3, 5, 6, 7, and 11, local public
19
agencies, CITY OF TUSTIN, a municipal corporation, TUSTIN COMMUNITY
20
REDEVELOPMENT AGENCY, a local public agency, MIDWAY CITY SANITARY
21
DISTRICT, a local public agency, LOS ALAMITOS COUNTY WATER DISTRICT, a
22
local public agency, SOUTH COAST WATER DISTRICT, a local public
23
agency, IMPROVEMENT DISTRICT NO. 1 OF SOUTH COAST WATER DISTRICT, an
24
improvement district, CITY OF SAN JUAN CAPISTRANO.. a municipal .
c
25
corporation, CITY OF SAN JUAN CAPISTRANO, COMMUNITY REDEVELOPMENT
v
26
AGENCY, a public body, STEPHEN B. JULIAN, citizen, resident and City
27
Manager of the City of San Juan Capistrano, and Executive Director of
®
28
the San Juan Capistrano Community Redevelopment Agency, CITY OF SANTA
dcc\1 2 •
I
ANA, a municipal corporation, COM14UNITY REDEVELOPMENT AGENCY OF THE
2
CITY OF SANTA ANA, a public body, CITY OF SEAL BEACH, a municipal
3
corporation, REDEVELOPMENT AGENCY OF THE CITY OF SEAL BEACH, a public
4
body, CITY OF STANTON, a municipal corporation, MARTHA V. WEISHAUPT,
5
citizen, resident and Mayor of the City of Stanton, STANTON
6
REDEVELOPMENT AGENCY, an independent public entity, PAUL VERELLEN,
7
citizen and resident of the City of Stanton and Chairman of the
8
Stanton Redevelopment Agency, CITY OF WESTMINSTER, a municipal
9
corporation, WESTMINSTER REDEVELOPMENT AGENCY, a public entity,
10
WESTMINSTER MUNICIPAL LIGHTING DISTRICT, a public entity, and CITY OF
11
WESTMINSTER SPECIAL DISTRICT AUGMENTATION TAX FUND, a special district
12
tax fund.
13
2. Definitions.
14
For purposes of this release, the term:
o;;
15
(a) "Related parties" includes, where applicable, each and all
W y,0
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16
of such party's respective predecessors, successors, and assigns; each
Z =
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17
and all of such party's heirs and personal representatives (if such
18
party is an individual); each and all of such party's past,present,
19
and future directors, officers, and elected or appointed members of
20
the party's governing body; each and all of such party's agents,
21
employees, representatives, and attorneys; and each and all persons
22
acting by, through, under, or in concert with such party or in concert
�3
with any or all of the foregoing persons.
24
(b) The "Claim" means any and all manner of action or actions,
25
cause or causes of action, in law or in equity, suits, -debts, liens,
N
26
contracts, agreements, promises, liabilities, claims, demands,
27
damages, losses, costs or expenses, of any nature whatsoever, known or
®.28
unknown, fixed or contingent, which any party now has*,or may hereafter
dre\1 3.
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3
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6
7
8
9
10
11
12
13
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18
19
20
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22
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28
have, against each or any of the persons such party hereby releases by
reason of those certain lawsuits now pending in the Superior Court of
the State of California in and for the County of Orange, and now or
pending in Division Three of the ;Fourth District of the California
Court of Appeal, as listed in Exhibit "A" attached hereto and
incorporated herein by reference, including all related cross-
complaints, as well as any matters, causes, or things whatsoever that
were, or have been, or could in any way have been, alleged in the
respective pleadings filed in said suits.
3. Re add .
.For a valuable consideration# the receipt and adequacy of which
are hereby acknowledged, each party on behalf of itself and its
Related Parties, does hereby fully release and forever discharge the
other party and the other party's Related parties, and each of them,
from the Claim and from any matters, causes, or things whatsoever that
have been or could in any way have been raised, demanded, or alleged
against the other party and the other party's Related Parties, or any
of them, arising out of, based upon, or relating to the Claim.
EACH PARTY ACKNOWLEDGES THAT 'IT HAS BEEN ADVISED BY LEGAL COUNSEL
AND IS FAMILIAR WITH THE PROVISIONS OF CALIFORNIA CIVIL CODE SECTION
1542 WHICH PROVIDES AS FOLLOWS:
"A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH
THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN
HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, '
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28
WHICH IF KNOWN BY HIM MOST HAVE MATERIALLY
AFFECTED HIS SETTLEMENT WITH THE DEBTOR."
EACH PARTY, BEING AWARE OF THIS CODE SECTION, HEREBY EXPRESSLY WAIVES
AND RELINQUISHES ALL RIGHTS AND BENEFITS WHICH IT MAY HAVE THEREUNDER,
AS WELL AS UNDER ANY OTHER STATUTt(S) OR COMMON LAW PRINCIPLES) OR
SIMILAR EFFECT.
5. Warranty Against Prior A_ s ignments .
Each party represents and warrants that it has not assigned or
transferred any interest in any Claim which it may have against the
persons which it releases under the term of this release, or any of
them, and each party agrees to indemnify and hold such persons, and
each of them, harmless from any liabilities, claims, demands, damages,
costs, expenses, and attorneys' fees incurred by such persons, or any
of them, as a result of any person asserting any such assignment or
transfer, or any rights or claims under any such assignment or
transfer. It is the intention of the parties that this indemnity does
not require payment as a condition precedent to recovery hereunder by
any indemnified person.
This release and the rights and obligations of the parties shall
be governed by, and construed and interpreted in all respects in
accordance with, the law of the State of California. Without limiting
the generality of the foregoing, when the context in which the words
are used in this release indicates that such is the intent, words in
the singular number shall include the plural and vice versa, all
pronouns, and variation thereof shall be deemed to refer to all
genders, and the term "person" shall include a corporation or other
entity, as well as a natural person.
5.
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1
3
4
5
6
7
8
9
10
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23
24
25
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7. Attornays' Fees
Each party agrees that if it hereafter commences any suit arising
out of, based upon, or relating to, or in any manner asserts against
the -other party and the other parity's Related Parties, or any*of them,
any claim released herein, it shall pay to each of them, in addition
to any other damages caused to any such person, that person's
reasonable costs and attorneys' fees incurred in defending or
otherwise responding to such suit or claim.
8. No Admission.
Each party understands and agrees that the execution of this
release shall not constitute or be construed as an admission of any
obligation, or of the validity of any claim whatsoever, by the persons
which are released under the terms of this release,or by any of them.
9. Counternarts .
This release may executed in one or more counterparts, which
together shall constitute a single document, and each of which shall
be an original for all purposes.
This release is executed by the undersigned on the dates at the
places indicated below.
Approved As To Form:
TERRY C. ANDRUS, COUNTY COUNSEL.
By
David R. Chaffee, Deputy
dcc\1
6.
COUNTY OF ORANGE
By_
Its
I
Approved
As To Form:
CAPISTRANO BAY PARK AND RECREATION
2
DISTRICT
Attorney
for CAPISTRANO BAY
By
3
PARK AND
RECREATION DISTRICT
4i
and LYNN
MUIR
Its
5
Lynn Muir
6
7
8
Approved
As To Form:
CITY OF COSTA MESA
9
10
By
Attorney
for CITY OF COSTA
MESA and
REDEVELOPMENT AGENCY
Its
11
OF THE CITY OF COSTA MESA
12
REDEVELOPMENT AGENCY OF THE
CITY OF COSTA MESA
13
14
By
Its
Opo
wow
Approved
As To Form:
w
16
CITY OF CYPRESS
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17
Attorney
for CITY OF CYPRESS
By
18
and CITY
OF CYPRESS RECREATION
AND PARR
DISTRICT, THE CYPRESS
Its
19
REDEVELOPMENT AGENCY and
MARGARET
ARNOLD, MAYOR
20
CITY OF CYPRESS RECREATION AND
PARK DISTRICT
21
22
By
23
24
THE CYPRESS REDEVELOPMENT AGENCY
,:
25
By
0
26
I t s
Margaret Arnold
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28
ep3/600
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® 28
Approved As To Form:
Attorney for CITY OF FOUNTAIN
VALLEY and GEORGE SCOTT
Approved As To Form:
Attorney for CITY OF
FULLERTON, FULLERTON REDEVELOP-
MENT AGENCY, ORANGE COUNTY
WATER DISTRICT, CITY OF IRVINE,
CITY OF LAGUNA BEACH, CITY OF
SAN CLEMENTE REDEVELOPMENT
AGENCY, CITY OF YORBA LINDA,
YORBA LINDA REDEVELOPMENT AGENCY,
YORBA LINDA LIBRARY DISTRICT,
FOUNTAIN VALLEY AGENCY FOR
COMMUNITY DEVELOPMENT, CITY OF
LA PALMA, LA PALMA REDEVELOPMENT
AGENCY, SANTIAGO COUNTY WATER
DISTRICT, TRI -CITIES MUNICIPAL
WATER DISTRICT, and ROSSMOOR
COMMUNITY SERVICE DISTRICT
ep3/600
CITY OF FOUNTAIN VALLEY
By
Its
George Scott
CITY OF FULLERTON
By
Its
FULLERTON REDEVELOPMENT AGENCY
By
Its
ORANGE COUNTY WATER DISTRICT
By
Its
CITY OF IRVINE
By
Its
CITY OF LAGUNA BEACH
By
Its
CITY OF SAN CLEMENTE
By
Its
SAN CLEMENTE REDEVELOPMENT AGENCY
By
Its
CITY OF YORBA LINDA
By
Its
YORBA LINDA REDEVELOPMENT AGENCY
By
Its
YORBA LINDA LIBRARY DISTRICT
By
Its
FOUNTAIN VALLEY AGENCY FOR
COMMUNITY DEVELOPMENT
By
Its
CITY OF LA PALMA
By
Its
Approved As To Form:
Attorney for CITY OF GARDEN
GROVE, GARDEN GROVE AGENCY
FOR COMMUNITY DEVELOPMENT
and J. TILMAN WILLIAMS
ep3/600
LA PALMA REDEVELOMENT AGENCY
By
Its
SANTIAGO COUNTY WATER DISTRICT
By
Its
TRI -CITIES MUNICIPAL WATER DISTRICT
By
Its
ROSSMOOR COMMUNITY SERVICE DISTRICT
By
Its
CITY OF GARDEN GROVE
By
Its
GARDEN GROVE AGENCY FOR COMMUNITY
DEVELOPMENT
By
Its
J. Tilman Williams
1
2
3
4
5
6
7
8
9
10
11
12
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Approved As To Form:
GARDEN GROVE SANITARY DISTRICT
Attorney for GARDEN GROVE By
SANITARY DISTRICT and Its
ROBERT MAIN
Approved As To Form:
Attorney(s) for CITY OF
HUNTINGTON BEACH, HUNTINGTON
BEACH REDEVELOPMENT AGENCY
and JOHN ERSKINE
Approved As To Form:
Attorney for LAGUNA BEACH
COUNTY WATER DISTRICT
Approved As To Form:
Attorney for CITY OF LA HABRA,
REDEVELOPMENT AGENCY OF
LA HABRA and JAMES A. FLORA
epi/600
Robert Main
CITY OF HUHTINGTON BEACH
By
Its
HUNTINGTON BEACH REDEVELOPMENT
AGENCY
By
Its
John Erskine
LAGUNA BEACH COUNTY WATER DISTRICT
By
Its
CITY• OF LA HABRA
By
Its
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8
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Approved As To Form:
Attorneys for CITY OF
LOS ALAMITOS and
CHARLES E. SYLVIA, MAYOR
Approved As To Form:
Attorneys for CITY OF MISSION
VIEJO, independently and as
Successor -in -Interest to the
Mission Viejo Community
Services District and
NORMAN P. MURRAY, MAYOR
ep3/600
REDEVELOPMENT AGENCY OF LA HABRA
By
Its
James A. Flora
CITY OF LOS ALAMITOS
Its
Charles E. Sylvia
CITY OF MISSION VIEJO,
independently, and as Successor -
In -Interest to the Mission Viejo
Community Services District
By
Its
Norman P. Murray
2
3
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Approved As To Form:
Attorney for CITY OF NEWPORT
BEACH and JOHN C. COS, JR. -
Approved As To Form:
Attorney for CITY OF
PLACENTIA, PLACENTIA
REDEVELOPMENT AGENCY
and JOHN 0. TYNES
CITY
By
OF
NEWPORT BEACH
Its
John
C.
Cox, Jr.
CITY
By
OF
PLACENTIA
Its
PLACENTIA REDEVELOPMENT AGENCY
By
Its
John
0.
Tynes
A v d As T orm:
COUNTY SANITATION DISTRICT NO. 1
Attor ey lf-onk-COUNTY By
SANITATION DISTRICTO .
1, 2, 3, 5, 6, 7, and 11 of Its
ORANGE COUNTY, CALIFORNIA;
CITY OF TUSTIN, TUSTIN COMMUNITY
REDEVELOPMENT AGENCY; MIDWAY COUNTY SANTIATION DISTRICT NO. 2
CITY SANITARY DISTRICT; LOS
ALAMITOS COUNTY WATER DISTRICT;
SOUTH COAST WATER DISTRICT and By
IMPROVEMENT DISTRICT NO. 1 OF
SOUTH COAST WATER DISTRICT Its
ep3/600
3
4
5
6
7
8
9
10
11
12
13
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COUNTY SANITATION DISTRICT NO. 3
By
Its
COUNTY SANITATION DISTRICT NO. 5
By
Its
COUNTY SANITATION DISTRICT NO. 6
By
Its
COUNTY SANITATION DISTRICT NO. 7
By
Its
COUNTY SANITATION DISTRICT NO. 11
By
Its
CITY OF TUSTIN
By
Its
TUSTIN COMMUNITY REDEVELOPMENT
AGENCY
By_
Its
21
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7
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Approved As To Form:
Attorney for CITY OF SAN JUAN
CAPISTRANO, CITY OF SAN JUAN
CAPISTRANO COMMUNITY REDEVELOP-
MENT AGENCY, and
STEPHEN B. JULIAN
ep3/600
MIDWAY CITY SANITARY DISTRICT
By
Its
LOS ALAMITOS
COUNTY WATER DISTRICT
By
Its
SOUTH COAST
WATER DISTRICT
By
Its
IMPROVEMENT
DISTRICT NO. 1 OF
SOUTH COAST
WATER DISTRICT
By
Its
CITY OF SAN
JUAN CAPISTRANO
By
Its
CITY OF SAN
JUAN CAPISTRANO
REDEVELOPMENT AGENCY
By
Its
1
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3
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7
8
9
10
11
12
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23
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Approved As To Form: CITY OF SANTA ANA
MENT AGENCY, MARTHA V. WIESHAUPT,
MAJOR, and PAUL VERELLEN
ep3/600
By
Attorney for CITY OF
SANTA ANA, COMMUNITY REDEVELOP-
Its
MENT AGENCY OF THE CITY OF
SANTA ANA
COMMUNITY REDEVELOPMENT AGENCY OF
THE CITY OF SANTA ANA
By
Its
Approved As To Form:
CITY OF SEAL BEACH
Attorneys for CITY OF SEAL
By
BEACH, REDEVELOPMENT AGENCY
OF THE CITY OF SEAL BEACH
Its
REDEVELOPMENT AGENCY OF THE
CITY OF SEAL BEACH
By
Its
Approved As To Form:
CITY OF STANTON
BY
Attorneys or CITY OF
STANTON, STANTON REDEVELOP-
Its
MENT AGENCY, MARTHA V. WIESHAUPT,
MAJOR, and PAUL VERELLEN
ep3/600
2
3)
4
5
6
7
8
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Approved As To Form:
Attorney for CITY OF
WESTMINSTER, WESTMINSTER
REDEVELOPMENT AGENCY,
WESTMINSTER MUNICIPAL
LIGHTING DISTRICT and
CITY OF WESTMINSTER SPECIAL
DISTRICT AUGMENTATION
TAX FUND
ep3/600
STANTON REDEVELOPMENT AGENCY
By_
Its
Martha V. Weishaupt
Paul Verellen
CITY OF WESTMINSTER
By
Its
WESTMINSTER REDEVELOPMENT AGENCY
By
Its
WESTMINSTER MUNICIPAL LIGHTING
DISTRICT
By
Its
CITY OF WESTMINSTER SPECIAL
DISTRICT AUGMENTATION AX FUND
By
Its
z
3
4
5
6
7,
8
9'
10
11
12
13
14
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23
24
25
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® 28
MUTUAL GENERAL RELEASE
1. Parties
The parties to this mutual general release (the "release")
are the COUNTY OF ORANGE, a political subdivision of the State of
California, CAPISTRANO BAY PARK AND RECREATION DISTRICT, a municipal
corporation, LYNN MUIR, Director of Capistrano Bay Park and Recreation
District, CITY OF COSTA MESA, a municipal corporation, REDEVELOPMENT
AGENCY OF THE CITY OF COSTA MESA, a public body, CITY OF CYPRESS, a
charter city, CITY OF CYPRESS RECREATION AND PARK DISTRICT,'an
independent special district, CYPRESS REDEVELOPMENT AGENCY, an
independent public entity, MARGARET ARNOLD, a citizen, resident and
Mayor of the City of Cypress, CITY OF FOUNTAIN VALLEY, a municipal
corporation, GEORGE SCOTT, a citiaen and -former Mayor of the City of
Fountain Valley, CITY OF FULLERTON, a public entity, FULLERTON
REDEVELOPMENT AGENCY, a public entity, ORANGE COUNTY WATER DISTRICT, a
public entity, CITY OF IRVINE, a public entity, CITY OF LAGUNA BEACH,
a public entity, CITY OF SAN CLEMtNTE, a public entity, SAN CLEMENTE
REDEVELOPMENT AGENCY, a public entity, CITY OF YORBA LINDA, a public
entity, YORBA LINDA REDEVELOPMENT AGENCY, a public entity, YORBA LINDA
LIBRARY DISTRICT, a public entity, FOUNTAIN VALLEY AGENCY FOR
COMMUNITY DEVELOPMENT, a public entity, CITY OF LA PALMA, a public
entity, LA PALMA REDEVELOPMENT AGENCY, a public entity, SANTIAGO
COUNTY WATER DISTRICT, a public entity, TRI -CITIES MUNICIPAL WATER
DISTRICT, a public entity, ROSSMOOR COMMUNITY SERVICE DISTRICT, a
public entity, CITY OF GARDEN GROVE, a municipal corporation, J.
TILMAN WILLIAMS, citizen, resident and Mayor of the City of Garden
Grove, GARDEN GROVE AGENCY FOR COMMUNITY DEVELOPMENT, a public body,
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GARDEN GROVE SANITARY DISTRICt, a political subdivision of the Statf
of California, ROBERT MARIN, a director of, and resident in, Garden
Grove Sanitary District, CITY OF HUNTINGTON BEACH, a municipal
corporation, JOHN ERSKINE, citizen, resident, and Mayor of the City
Huntington Beach, HUNTINGTON BEACH REDEVELOPMENT AGENCY, a public
body, LAGUNA BEACH COUNTY WATER DISTRICT,- a local special district,
CITY OF LA HABRA, a municipal corporation, JAMES A. FLORA, citizen,
resident and Mayor of the Cityof La Habra, REDEVELOPMENT AGENCY OF
HABRA, a public body, CITY OF LOS ALAMITOS, a charter city, CHARLES
SYLVIA, citizen, resident and Mayor of the City of Los Alamitos, CIT
OF MISSION VIEJO, a municipal corporation and as successor in intere:
to the Mission Viejo Community Services District, NORMAN P. MURRAY,
citizen, resident and Mayor .of the City of Mission Viejo, CITY OF
NEWPORT BEACH, a municipal corporation, JOHN C. COX, JR., citizen,
resident and Mayor of the City of Newport Beach, CITY OF PLACENTIA,
municipal corporation, JOHN O. TYNES, citizen, resident and Mayor of
the City of Placentia, PLACENTtA REDEVELOPMENT AGENCY, a public body,
COUNTY SANITATION DISTRICT NOS« 1, 2, 3, 5, b, 7, and 11, local publi
agencies, CITY OF TUSTIN, a municipal corporation, TUSTIN COMMUNITY
REDEVELOPMENT AGENCY, a local public agency, MIDWAY CITY SANITARY
DISTRICT, a local public agency, LOS ALAMITOS COUNTY WATER DISTRICT,
local public agency, SOUTH COAST WATER DISTRICT, a local public
agency, IMPROVEMENT DISTRICT NO. 1 OF SOUTH COAST WATER DISTRICT, an
improvement district, CITY OF SAN JUAN CAPISTRANO, a municipal
corporation, CITY OF SAN JUAN CAPISTRANO, COMMUNITY REDEVELOPMENT
AGENCY, a public body, STEPHEN B. JULIAN, citizen, resident and City
Manager of the City of San Juan Capistrano, and Executive Director of
the San Juan Capistrano Community Redevelopment Agency, CITY OF SANTA
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WHICH IF KNOWN BY HIM MOST HAVE MATERIALLY
AFFECTED HIS SETTLEMENT WITH THE DEBTOR."
EACH PARTY, BEING AWARE OF THIS CODE SECTION, HEREBY EXPRESSLY WAIVES
AND RELINQUISHES ALL RIGHTS AND BENEFITS WHICH IT MAY HAVE THEREUNDER,
AS WELL AS UNDER ANY OTHER STATUTO(S) OR COMMON LAW PRINCIPLES) OR
SIMILAR EFFECT.
5. Warranty Against Prior A$sign ants.
Each party represents and warrants that it has not assigned or
transferred any interest in any Claim which it may have against the
persons which it releases under the term of this release, or any of
them, and each party agrees to indemnify and hold such persons, and
each of them, harmless from any liabilities, claims, demands, damages,
costs, expenses, and attorneys' fees incurred by such persons, or any
of them, as.a result of any person asserting -any such assignment or
transfer, or any rights or claims under any such assignment or
transfer. It is the intention of the parties that this indemnity does
not require payment as a condition precedent to recovery hereunder by
any indemnified person.
6. Construction and InterDrotation.
This release and the rights and obligations of the parties shall
be governed by, and construed and interpreted in all respects in
accordance with, the law of the State of California. Without limiting
the generality of the foregoing, when the context in which the words
are used in this release indicates that such is the intent, words in
the singular number shall include the plural and vice versa, all
pronouns, and variation thereof shall be deemed to refer to all
genders, and the term "person" shall include a corporation or other
entity, as well as a natural person.
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7. Attorneys* Fees
Each party agrees that if it hereafter commences any suit arising
out of, based upon, or relating to, or in any manner asserts against
the other party and the other party's Related Parties, or any'of them,
any claim released herein, it shall pay to each of them, in addition
to any other damages caused to any such person, that person's
reasonable costs and attorneys' fees incurred in defending or
otherwise responding to such suit or claim.
8. No Admission.
Each party understands and agrees that the execution of this
release shall not constitute or be construed as an admission of any
obligation, or of the validity of any claim whatsoever, by the persons
which are released under the terms of this release,or by any of them.
9. Counteroaarrt_s .
This release may be executed in one or more counterparts, which
together shall constitute a single document, and each of which shall
be an original for all purposes.
This release is executed bythe undersigned on the dates at the
places indicated below.
Approved As To Form:
TERRY C. ANDRUS, COUNTY COUNSEL
By
David R. Chaffee, Deputy
6.
COUNTY OF ORANGE
By_
Its
CAPISTRANO BAY PARR AND RECREATION
DISTRICT
By
Its
Lynn Muir
CITY OF COSTA MESA
By
Its
REDEVELOPMENT AGENCY OF THE
CITY OF COSTA MESA
By
Its
CITY OF CYPRESS
By
Its
CITY OF CYPRESS RECREATION AND
PARK DISTRICT
By
THE CYPRESS REDEVELOPMENT AGENCY
By
Its
Margaret Arnold
1
Approved
As To Form:
2
Attorney
for CAPISTRANO BAY
3
PARR AND
RECREATION DISTRICT
4 i
and LYNN
MUIR
5
6
7
8
Approved
As To Form:
9
10
Attorney
or CITY OF COSTA
MESA and
REDEVELOPMENT AGENCY
11
OF THE CITY OF COSTA MESA
12
13
14
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Approved
As To Form:
16
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Attorney
for CITY OF CYPRESS
18
and CITY
OF CYPRESS RECREATION
AND PARK
DISTRICT, THE CYPRESS
19
REDEVELOPMENT AGENCY and
MARGARET
ARNOLD, MAYOR
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12
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24
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ep3/600
CAPISTRANO BAY PARR AND RECREATION
DISTRICT
By
Its
Lynn Muir
CITY OF COSTA MESA
By
Its
REDEVELOPMENT AGENCY OF THE
CITY OF COSTA MESA
By
Its
CITY OF CYPRESS
By
Its
CITY OF CYPRESS RECREATION AND
PARK DISTRICT
By
THE CYPRESS REDEVELOPMENT AGENCY
By
Its
Margaret Arnold
1
2
3 it
4 (j
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8
9
10
11
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14
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19
20
21
22
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Approved As To Form: CITY OF FOUNTAIN VALLEY
ep3/600
By
Attorney for CITY OF FOUNTAIN
VALLEY and GEORGE SCOTT
Its
George Scott
Approved As To Form:
CITY OF FULLERTON
Attorney for CITY OF
By
FULLERTON, FULLERTON REDEVELOP-*
MENT AGENCY, ORANGE COUNTY
Its
WATER DISTRICT, CITY OF IRVINEr
CITY OF LAGUNA BEACH, CITY OF
SAN CLEMENTE REDEVELOPMENT
FULLERTON REDEVELOPMENT AGENCY
AGENCY, CITY OF YORBA LINDA,
YORBA LINDA REDEVELOPMENT AGENCY,
YORBA LINDA LIBRARY DISTRICT,
By
FOUNTAIN VALLEY AGENCY FOR
COMMUNITY DEVELOPMENT, CITY OF
Its
LA PALMA, LA PALMA REDEVELOPMENT
AGENCY, SANTIAGO COUNTY -WATER
'DISTRICT, TRI -CITIES MUNICIPAL
ORANGE COUNTY WATER DISTRICT
WATER DISTRICT, and ROSSMOOR
COMMUNITY SERVICE DISTRICT
BY
Its
CITY OF IRVINE
BY
Its
CITY OF LAGUNA BEACH
By
Its
ep3/600
1
2
CITY OF SAN CLEMENTE
3
By
4
Its
S
6
SAN CLEMENTE REDEVELOPMENT AGENCY
7
By
8
Its
9
10
CITY OF YORBA LINDA
11
By
12
Its
13
14
YORBA LINDA REDEVELOPMENT AGENCY
By.
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Its
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YORBA LINDA LIBRARY DISTRICT
18
By
19
Its
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-
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FOUNTAIN VALLEY AGENCY FOR
COMMUNITY DEVELOPMENT
22
23
By
24
Its
,:
25
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CITY OF LA PALMA
7
By
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28
Its
1
3
4
5
6
7'
8
9'
10
11
12
13
14
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19
20
21
22
23
24
25
26
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Approved As To Form:
Attorney for CITY OF GARDEN
GROVE, GARDEN GROVE AGENCY
FOR COMMUNITY DEVELOPMENT
and J. TILMAN WILLIAMS
ep3/600
LA PALMA REDEVELOMENT AGENCY
By
Its
SANTIAGO COUNTY WATER DISTRICT
By
Its
TRI -CITIES MUNICIPAL WATER. DISTRIC'.
By
Its
ROSSMOOR COMMUNITY SERVICE DISTRICZ
By
Its
CITY OF GARDEN GROVE
By
Its
GARDEN GROVE AGENCY FOR COMMUNITY
DEVELOPMENT
By
Its
J. Tilman Williams
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2
3
4'
5
6
7
8
9
10
11
12
13
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18
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20
21
22
23
24
25
26
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Approved As To Form:
Attorney f or GARDEN GROVE
SANITARY DISTRICT and
ROBERT MAIN
Approved As To Form:
Attorney(s) for CITY OF
HUNTINGTON BEACH, HUNTINGTON
BEACH REDEVELOPMENT AGENCY
and JOHN*ERSKINE
Approved As To Form:
Attorney or LAGUNA BEACH
COUNTY WATER DISTRICT
Approved As To Form:
Attorney for CITY OF LA HABRA,
REDEVELOPMENT AGENCY OF
LA HABRA and JAMES A. FLORA
epi/600
GARDEN GROVE SANITARY DISTRICT
By
Its
Robert Main
CITY OF HUNTINGTON BEACH
By
Its
HUNTINGTON BEACH REDEVELOPMENT
AGENCY
BY
Its
John Erskine
LAGUNA BEACH COUNTY WATER DISTRICT
By
Its
CITY - OF LA HABRA
By
Its
1
2
3
4
5
6
7
8
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10
11
12
13
14 I
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19
20
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23
24
25
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Approved As To Form:
Attorneys for CITY OF
LOS ALAMITOS and.
CHARLES E. SYLVIA, MAYOR
Approved As To Form:
Attorneys for CITY OF MISSION
VIEJO, independently and as
Successor -in -Interest to the
Mission Viejo Community
Services District and
NORMAN P. MIIRRAY, MAYOR
ep3/600
REDEVELOPMENT AGENCY OF LA HABRA
By
Its
James A. Flora
CITY OF LOS ALAMITOS
By
Its
Charles E. Sylvia
CITY OF MISSION VIEJO,
independently, and as Successor -
In -Interest to the Mission Viejo
Community Services District
By_
Its
Norman P. Murray
2
3
4
6
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8
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10
11
12
13
14
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19
20
21
22
23
24
25
26
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Approved As To Form:
Attorney for CITY OF NEWPORT
BEACH and JOHN C. COS, JR.
Approved As To Form:
Attorney for CITY OF
PLACENTIA, PLACENTIA
REDEVELOPMENT AGENCY
and JOHN 0. TYNES
Apprc v
A$torhey Ifo
SANITATION DISTRIOS.
1, 2, 3, 5, 6, 7, and 11 of
ORANGE COUNTY, CALIFORNIA;
CITY OF TUSTIN, TUSTIN COMMUNITY
REDEVELOPMENT AGENCY= MIDWAY
CITY SANITARY DISTRICT; LOS
ALAMITOS COUNTY WATER DISTRICT;
SOUTH COAST WATER DISTRICT and
IMPROVEMENT DISTRICT NO. 1 OF
SOUTH COAST WATER DISTRICT
ep3 / 600
CITY OF NEWPORT BEACH
By
Its
John C. Cox, Jr.
CITY OF PLACENTIA
By
Its
PLACENTIA REDEVELOPMENT AGENCY
By
Its
John 0. Tynes
COUNTY SANITATION DISTRICT NO. I
By_
Its
COUNTY SANTIATION DISTRICT NO. 2
By_
Its
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8
9
10
11
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1S
2C
ep3/600
COUNTY SANITATION DISTRICT NO. 3
By
Its
COUNTY SANITATION DISTRICT NO. 5
By
Its
COUNTY SANITATION DISTRICT NO. f
By
Its
COUNTY SANITATION DISTRICT NO. 7
By
Its
COUNTY SANITATION DISTRICT NO. 11
By
Its
CITY OF TUSTIN
By
Its
TUSTIN COMMUNITY REDEVELOPMENT
AGENCY
By
Its
8
9
10
,
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18
19
20
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22
23
24
25
26
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® 28
Approved As To Form:
Attorney for CITY OF SAN JUAN
CAPISTRANO, CITY OF SAN JUAN
CAPISTRANO COMMUNITY REDEVELOP-
MENT AGENCY, and
STEPHEN B. JULIAN
ep3/600
MIDWAY CITY SANITARY DISTRICT
By
Its
LOS ALAMITOS COUNTY WATER DISTRICT
By
Its
SOUTH COAST WATER DISTRICT
By
Its
IMPROVEMENT DISTRICT NO. I OF
SOUTH COAST WATER DISTRICT
By
Its
CITY OF SAN JUAN CAPISTRANO
By
Its
CITY OF SAN JUAN CAPISTRANO
REDEVELOPMENT AGENCY
By_
Its
1
2
1
4
S
6
7
8
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10
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14
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19
20
21
17
23
24
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Approved As To Form.
Attorney or CITY OF
SANTA ANA, COMMUNITY REDEVELOP-
MENT AGENCY OF THE CITY OF
SANTA ANA
Approved As To Form:
Attorneys for CITY OF SEAL
BEACH, REDEVELOPMENT AGENCY
OF THE CITY OF SEAL BEACH
Approved As To Form:
CITY OF SANTA ANA
By
Its
COMMUNITY REDEVELOPMENT AGENCY OF
THE CITY OF SANTA ANA
B ----------------y
Its
CITY OF SEAL BEACH
By
Its
REDEVELOPME 4T AGENCY OF THE
CITY OF SEAL BEACH
By
Its
CITY OF STANTON
Attorneys for CITY OF By
STANTON, STANTON REDEVELOP_ Its
MENT AGENCY, MARTHA V. WIESHAUPT, -
MAJOR, and PAUL VERELLEN
ep3/600
1
2
3
4
5
6
7
8
9
10
11
12
13
-14
V
of � t5
0
W 0wV
V
W
16
0Z=
134
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V
18
19
20
21
23
24
25
26
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Approved As To Form:
Attorney for CITY OF
WESTMINSTER, WESTMINSTER
REDEVELOPMENT AGENCY,
WESTMINSTER MUNICIPAL
LIGHTING DISTRICT and
CITY OF WESTMINSTER SPECIAL
DISTRICT AUGMENTATION
TAX FUND
ep3/600
STANTON REDEVELOPMENT AGENCY
By
Its
Martha V. Weishaupt
Paul Verellen
CITY OF WESTMINSTER
By
Its
WESTMINSTER REDEVELOPMENT AGENCY
BY
Its
WESTMINSTER MUNICIPAL LIGHTING
DISTRICT
By
Its
CITY OF WESTMINSTER SPECIAL
DISTRICT AUGMENTATION AX FUND
By
Its