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SETTLEMENT AGREEMENT AND RELEASE
This Settlement Agreement and Release (the "Agreement") is entered into by
Ashbritt, Inc., a Florida corporation ("Ashbritt°) and by the City of Miami Beach, a Florida
municipal corporation, and hereinafter referred to as ("City") collectively, the ("Parties").
The Parties agree and stipulate to the following:
1. A dispute has arisen between the Parties surrounding those claims and
disputes arising out of the claim for Disaster Recovery Services (hereinafter "Service
Agreement"). performed by Ashbritt required as part of the emergency response to
hurricanes Katrina and Wilma in .2004 and 2005, pursuant to an agreement between the
City and. Ashbritt for Disaster Recovery Services dated April 6, 2004.
2. The Parties have reached an agreement as to the dispute and desire to
fully and finally resolve any and all claims and/or disputes against each other and their
respective agents, employees, officers, independent contractors, servants, and
representatives concerning, relating to, or in any way arising out of the dispute, and all
other matters regarding the City's obligations, whether actually communicated by the
City and/or its respective agents, employees, officers, independent contractors,
servants, and representatives, or which is incorporated by.mere implication within the
City's Codes and Ordinances, Resolutions, Florida Statutory Law and Florida Case
precedent, and any other matters described and/or defined herein.
Based on the above and in consideration of mutual covenants and other valuable
consideration, the receipt and sufficiency of which is hereby acknowledged, the Parties
agree to the following:
A. The foregoing recitals are true and correct and are incorporated herein.
B. The City shall cause to be paid to Ashbritt the sum of $682,181.95 for the
remaining balance of Disaster Recovery Services. This payment shall represent full and
final payment and settlement of all monies due and owing to Ashbritt from the City. The
release and all other conditions of this Agreement are contingent upon payment of said
amount. Payment shall be made by delivering a check payable to Ashbritt.
C. The City agrees that, consistent with the Service Agreement between the
City and Ashbritt, Ashbritt will be offered the first opportunity to provide disaster
recovery services from among the City list of eligible contractors in the event of such
need by the City for the -2008, 2009 and 2010 hurricane season. The first opportunity
for Ashbritt to respond as a disaster services provider may be extended for future years
at the sole discretion of the City. This agreement is not intended to provide an exclusive
guarantee to Ashbritt that other emergency service provider services will not be utilized
by the City or a guarantee for any specific amount or type of services and is subject
Ashbritt's performance of services at a level acceptable to the City.
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D. Other than as may beset forth in this Agreement, each party shall bear
their own attorneys' fees and costs, if any, incurred in connection with the Dispute and
this Agreement. '
E. The Parties understand and agree that no party admits liability of any ort
by reason .of the above incidents, acts, casualties, events, representations, omissions,
conduct, or interpretation. The Parties also understand and agree that this Agreement
constitutes the -good faith compromise. of a Dispute and is made. in good faith to
terminate any further controversy respecting all claims for damages, causes•of action;
or potential liability which could have been ascertained by reasonable: diligence which.
either Party to this Agreement may have asserted now, or may assert in the future
because of any damages, incidents, acts, casualties, or events, described or alluded.to
in this Agreement.
F: The Parties hereby release; acquit, and forever discharge each other and
their past, present, and future shareholders, directors, officers, employees, principals,
agents, servants, independent- contractors, representatives, parent corporations;
subsidiaries, afFliates, predecessors, successors; assigns, attorneys, and insurers from
any and all actions, causes of action, claims, counterclaims, demands, damages, fines,
penalties, assessments, costs; loss of services, expenses, interest, attorneys' fees and
compensation whatsoever, in any way relating to, or arising out of the Dispute; and all
other matters defined and/or described herein, whether known or unknown, accrued or
unaccrued, asserted or unasserted.
G. The Parties agree to not instigate, raise, or pursue any complaint or action
concerning any other party or their past, present, and future shareholders, directors,
officers, employees, principals, agents, servants, independent contractors,
representatives, .parent- corporations, subsidiary corporations,... predecessors,
successors, assigns, attorneys, and insurers, within any Florida State Jurisdiction or
governmental agency which may maintain jurisdiction of these disputed issues. Further,
the Parties agree to drop, stop., and/or end any such actions or complaints and to take
all necessary actions to seek dismissal of same.
H. The Parties warrant and represent that they have not sold, assigned,
transferred, conveyed, or otherwise disposed of any of the claims, demands,
obligations, or causes of action referred to in this Agreement.
1. The Parties declare and represent that they were not induced to enter into
this Agreement by any representations respecting the nature and extent of any
damages, legal liability, or financial responsibility made by any Party or their
representatives.
J. .This. Agreement may be executed in any number of counterparts, each of
which shall be deemed an original, but all of which together shall constitute one in the
same instrument. A copy of this Agreement transmitted by telefacsimile shall be
deemed an original. ,
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K. The Parties acknowledge that this: Agreement constitutes the entire
agreement. They further acknowledge that they have read it and understand it; that the
terms and conditions of this Agreement were arrived at in arm's-length. negotiations
between the Parties with all Parties provided the opportunity to seek the advice of legal
counsel; that each Rarty's legal counsel did or could have reviewed this Agreement; and
that each Party has given due and full considerationto the legal position of the other: in
regard to the provisions contained herein: . .
L. No modification, waiver, amendment, discharge, or change of this
Agreement shall be valid- unless the same is in writing and signed by-.the Party against
..which the enforcement of such modification; waiver, amendment, discharge, or change
is sought.
M. This Agreement shall be construed, enforced and interpreted in
accordance with the laws of the State of Florida. In the event that an ambiguity or
question of intent or interpretation arises, this Agreement shall be construed as if crafted
jointly by each of the Parties hereto and no presumptions or burdens of proof shall arise
favoring any party by virtue of the authorship of-any of the provisions.of the Agreement.
The Parties jointly conclude that should this Agreement be challenged by any of the
Parties, that venue for bring such challenges shall take place in Miami-Dade County,
Florida.
N. In the event any provision, term or condition of this Agreement, on behalf
of either party, thereto shall be inapplicable, invalid, illegal or unenforceable in any
respect, the remainder of this Agreement and application of such provisions; terms or
conditions shall not be affected thereby, and shall be enforced to the fullest extent
permitted by law.
O. It is hereby acknowledged by the Parties that nothing contained in-this
Agreement was intended to serve as a waiver of sovereign immunity, as set forth and
codified in Section 768.28 of -the Florida Statutes, by the City to: which sovereign
immunity is applicable in the recovery of damages in tort for money damages against
the state or its agencies or subdivision or injury or loss of property, personal injury, or
death caused by the negligent or wrongful .act or omission of any employee of the
agency or subdivision while acting within the scope of the employee's office or
employment.-
P. The parties expressly acknowledge that it is not their intent to create or.
confer any rights or obligations in or. upon. ay third person or entity under this
Agreement. None of the Parties intend to directly or substantially benefit a third party by
this Agreement. The Parties agree that there are no third party beneficiaries to this
Agreement and that no third party shall be entitled to assert a claim against any of the
parties based upon this Agreement. Nothing herein shall be construed as consent by
an agency or political subdivision of the State of Florida to be sued by third parties in
any manner arising out of this Agreement, or other obligations, whether known or
unknown to the Parties.
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IN WITNESS WHEREOF, the parties have set their hands and seals on the day...
and date first written above: ~ `
STATE OF FLORIDA
COUNTY OF MIAMI-DADE
ASHBRITT,
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(~ The. foregoing instrum nt was ckpowledged before me this ~ ~ day of
F--~LQ,h~:(~rt-~ 2009 by 4 ~r as . (',~~U of Ashbritt,
Inc., -who is personally known.' to me or who .has produced
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STATE OF FLORIDA
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CITY OF MIAM! BEACH
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n N Th, D foregoing instrument was acknowledged before me this ~_ day of
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the City of Miami Beach; who is pers y kno o me o who has produced--
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Name: ~GGC..ovr')'J I~- W~.GZ~~lt~*~
(Print Name)
Notary Public -State of Florida
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