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R7G-Execute Settlement Agmt And Mutual Release South Pointe Phase II ProjectCOMMISSION ITEM SUMMARY Intended Outcome Item Summary/Recommendation : Horizon was issued the second Notice to Proceed on May 4,2009, and was scheduled to perform the work within 577 calendar days, plus an additional 166 calendar day time extension for additional work. Horizon achieved Substantial Completion of the Project in March 20'11, and Final Completion in May 2011, in accordance with the established Contract Time. On October 25, 2011, the City received a claim letter from Horizon requesting a mediation conference to resolve outstanding claims relating to the Contract. Horizon's Mediation Statement and Summary in the arnount of $'1,724,733.44, was submitted in December 2011 and it included the following claims: 1) Dewatering lmpacts 2) Pipe Testing Criteria Changes 3) DERM Tree Permit lmpacts 4) Contract Drawing Changes & Unpaid Changes 5) Undisputed Retainage; Prompt Payment Act lnterest On January 6,2012, the City and Horizon, met for mediation, which resulted in an lnterim Settlement Agreement which addressed the above mentioned claim items # 4 in parl and item # 5 in full. The settled amounts are reflected in the Supplement to lnterim Settlement Agreement (Exhibit C). ln addition, the City agreed to review and discuss the remaining claims until impasse or resolution/settlement. The City hired engineering consulting firm Corzo Castella Carballo Thompson Salman, P.A (C3TS), reassigned to and now known as Stantec Consulting Services lnc. (Stantec), to perform an impartial professional analysis and delermine the validity of the remaining claimed items. On March 5,.2012, a second .mediation meeting was held to dlscuss the remaining claims. The settled amounts are reflected in the Supplement to lnterim Settlement Agreement previously referenced. The Contractor and the City came to an impasse on items # 1,#2, # 3 and part of # 4. Several months later Horizon submitled addilional information and data substantiating the claims previously denied. The City tasked Stantec with the review of the supplemental information received from Horizon. On March 20, 2014, a final negotiation meeting was held between the City and Horizon where they agreed to a full and final setllement of all Contractor claims for damages against the City for the Scope of work pertaining to the Neighborhood 12 - South Pointe Phase ll Project, in the total amount of $490,000 (see Exhibit D). THE ADMINISTRATION RECOMMENDS ADOPTING THE RESOLUTION Board Recommendation: Financial Clerk's Office AGEI{OA ITEU OATE Condensed Title: A Resolution Of The Mayor And City Commission Of The City Of Miami Beach, Florida, Approving And Authorizing The Mayor And City Clerk To Execute A Settlement Agreement And Mutual Release Between The City Of Miami Beach (City) And Horizon Contractors, lnc., (Contractor) ln The Amount Of $490,000 To Settle All Outstanding Claims Pertaining To The Neighborhood 12 - South Pointe Phase ll Project; Funding For The Final Payment To The Contractor ls Subject To The Sth Amendment To The Capital Budget For Fiscal Year 2013114To Be Presented AtThe June 1'|,.2014 Commission Meeti Build and maintain infrastructure with full accou Su Data (Survevs. Environmental Scan. etc.l: N/A Source of .. Funas: D)--,Amount Account 1 $490,000 389-2332-069357u f1u 2 OBPI vl Total Financlal lmpact Summary: $490,000 E MIAMIBEACH 676 E MIAMI BEACH Ciry of Miomi Beach. 1700 Convention Cenier Drive, Miomi Beoch, Florido 33139, www.miomibeochfl.gov COMMISSION MEMORANDUM Mayor Philip Levine and Members the City FROM: Jimmy L. Morales, City Manager DATE: June 11,2014 SUBJECT: A RESOLUTION OF THE MAY OF MIAMI BEACH, FLORIDA, MAYOR AND CITY CLERK TO NG AND AUTHORIZING THE CUTE A SETTLEMENT AGREEMENT AND MUTUAL RELEASE BETWEEN THE CtTy OF MtAMt BEACH (CtTy) AND HORTZON CONTRACTORS, tNC., (CONTRACTOR) lN THE AMOUNT OF $49O,OOO TO SETTLE ALL OUTSTANDING CLAIMS PERTAINING TO THE NEIGHBORHOOD 12 - SOUTH POINTE PHASE II PROJECT; FUNDING FOR THE FINAL PAYMENT TO THE CONTRACTOR IS SUBJECT TO THE sTH AMENDMENT TO THE CAPITAL BUDGET FOR FISCAL YEAR 2013114 TO BE PRESENTED AT THE JUNE 11, 2014 COMMTSSION MEETING. ADMINISTRATION RECOMMENDATION The Administration recommends adopting the Resolution KEY INTENDED OUTCOME SUPPORTED Build and maintain priority infrastructure with full accountability FUNDING Amount $490,000.00 BACKGROUND On December 10,2008, the CityCommission approved the award of a construction contractto Horizon Contractors, lnc. (Horizon) in the amount of $7,683,901, for the construction of the Neighborhood 12 -South Pointe RDA Phase ll Right of Way lnfrastructure lmprovement Project. During the construction of the project, additional scope of work including the 3'd Street lmprovements between Michigan and Washington Avenues, and a 12-inch water main along 4th Street between Lenox Avenue and Washington Avenue were added to the Project, increasing the Contract amount to a total of $9,581,624. AND CITY COMMISSION OF THE CITY Account Number 389-2332-0693s7 677 Commission Memorandum -Horizon Construction Settlement Agreement Page 2 of 4 The Project limits include the area bounded to the north by Sth Street, to the south by 2nd Street, to the east by Washington Avenue and to the west by Alton Road. The Project scope of work included the replacement of existing water lines within the alleyways and along 4th Street; the installation of new storm water infrastructure throughout the project area; streetscape improvements, including pavement and hardscape; traffic calming measures such as bump- outs; enhanced pedestrian access; landscaping and irrigation; pedestrian lighting and parking improvements. ANALYSIS Horizon was issued the second Notice to Proceed on May 4, 2009, and was scheduled to perform the work within 577 calendar days, plus an additional 166 calendar day time extension for additional work. Horizon achieved Substantial Completion of the Project in March 2011, and Final Completion in May 2011 , in accordance with the established Contract Time. On October 25,2011 , the City received a claim letter from Horizon (Exhibit A) requesting a mediation conference to resolve outstanding claims relating to the Contract. Horizon's Mediation Statement and Summary in the amount of $1 ,724,733.44 (Exhibit B), was submitted in December 2011 and it included the following claims: 1) Dewatering lmpacts 2) Pipe Testing Criteria Changes 3) DERM Tree Permit lmpacts 4) Contract Drawing Changes & Unpaid Changes 5) Undisputed Retainage; Prompt Payment Act lnterest $ 467,090.40 $ 701,098.30 $ 60,725.45 $ 179,296.96$ 316,522.33 $1,724,733.44 On January 6, 2012, the City and Horizon, met for mediation, which resulted in an lnterim Settlement Agreement which addressed the above mentioned claim items # 4 in part and item # 5 in full. The settled amounts are reflected in the Supplement to lnterim Settlement Agreement (Exhibit C). ln addition, the City agreed to review and discuss the remaining claims until impasse or resolution/settlement. The City hired engineering consulting firm Corzo Castella Carballo Thompson Salman, P.A (C3TS), reassigned to and now known as Stantec Consulting Services lnc. (Stantec), to perform an impartial professional analysis and determine the validity of the remaining claimed items. On March 5, 2012, a second mediation meeting was held to discuss the remaining claims. The settled amounts are reflected in the Supplemenl to lnterim Settlement Agreement previously referenced. The Contractorand the Citycame to an impasse on items #1,#2,#3 and part of# 4. On February 2013, Horizon submitted additional information and data substantiating the claims previously denied. The City tasked Stantec with the review of the supplemental information received from Horizon. On March 20, 2014, a final negotiation meeting was held between the City and Horizon where they agreed to a full and final settlement of all Contractor claims for damages against the City for the Scope of work pertaining to the Neighborhood 12 - South Pointe Phase ll Project, in the total amount of $490,000 (see Exhibit D). 678 Commission Memorandum -Horizon Construction Seftlement Agreement Page 3 of 4 The result of claim reviews and subsequent meetings between Horizon, City staff and Stantec, as well as the final negotiated amounts are depicted below and listed in Exhibit E - Summary of Horizon Claim Settlement. 1) Dewaterinq lmpacts Horizon's contract required the installation of the stormwater syslem in dry conditions and maintaining the groundwater levels below the bottom of excavation. During the Miami Dade County Depa(ment of Environmental Resource Management (DERM) Dewatering Permit application process, several areas within the project limits were determined to be contaminated. Consequently, Horizon was unable to obtain a dewatering permit despite the efforts of both the City and Contractor. As such, Horizon proceeded with the installation of the stormwater system "in the wet", by implementing additional crews to complete the installation of the pipe on schedule. The Project Baseline Schedule submitted by Horizon together with their bid accounted for 141 crew shifts (crew work days), at the end of the installation, Horizon had utilized 241 crew shifts to complete the stormwater system installation. Horizon claimed the amount of $467,090 for costs associated with the additional crew time. The January 6, 2012 and March 5, 2012 mediations resulted in an impasse on this item. Following review by City staff and Stantec of the supplemental documentation submitted by Horizon, after the previous mediations, it was determined that additional crew hours were, in fact, utilized to complete the project on time. The total claim amount was negotiated down to $189,871 . Pipe Testinq Criteria Changes At the time of Bid issuance, the stormwater pipe testing criteria required infiltration testing for only pipes with the crown of pipe below elevation 2.28 Bay Datum, which excluded approximately 25 percent of the installed pipes from required testing. Following the installation of the stormwater system, the pipe testing criteria was revised by the City to include testing of all pipes for infiltration, as well as, testing during high tide regardless or pipe depth. Horizon's claim in the amount $701 ,098, was for pipe cleaning efforts due to excessive siltation of the pipes resulting from the "in the wet" installation. This item resulted in an impasse atthe January 6,2012 and the March 5, 2012 mediations. Following review by City staff and Stantec of the supplemental documentation submitted by Horizon, it was determined that additional effort resulted from cleaning of "in the wet" installed pipes and the new criteria stipulated by the City. The total claim amount was negotiated down to $264,294. DERM Tree Permit lmpactsA DERM tree permit was also required for Horizon to complete the landscape improvements. Horizon claims that due to issues outside their control, the required DERM Tree Permit could not be obtained, therefore causing project delays. The January 6, 2012 mediation resulted in the relection of this claim. ln a subsequent joint review by City staff and Slantec this claim was also rejected. 2l 3) 679 Commission Memorandum -Horizon Construction Settlement Agreement Page 4 of 4 4) Gontract Drawinq Chanqes. Unpaid Chanqes. Unforeseen Conditions & Conflicts This claim was partially addressed at the January 6, 2012, lnterim Settlement Agreement with Horizon. The outstanding issue on this claim pertained to Contract Drawing Changes. Shortly after the award of the Project, the City revised the plans and specifications, adding certain scope of work, including Revision 4, which consisted of parking reconfiguration on Jefferson Avenue and certain storm drainage revisions. On February 9,2010, Horizon provided the City with a proposed change order in the amount of $63,596, for the costs associated with this revision. The change order request was rejected by the City as there was not sufficient back-up documentation at that time to substantiate the proposed change order. The portion of this claim related to Revision 4 changes resulted in an impasse at the January 6,2012 and the March 5, 2012 mediations. ln a subsequent joint review by City staff and Stantec of supplemental documents submitted by Horizon this claim was negotiated down to $35,835. 5) Undisputed Retainaoe: Prompt Pavment Act lnterest. Contract Balance As a part of the January 6, 2012, lnterim Settlement Agreement Horizon was paid the negotiated amount of $307,272. The total amount of the Final Settlement Agreement of all claims for damages against the City for the scope of work pertaining to the Neighborhood 12 -South Pointe RDA Phase ll Project is in the amount of $490,000. CONCLUSION The Administration recommends that the Mayor and Commission adopt the Resolution Approving and Authorizing the Mayor and City Clerk to execute the Settlement Agreement and Mutual Release between the City of Miami Beach and Horizon Contractors, lnc., in the amount of $490,000 to settle all outstanding claims pertaining to the Neighborhood 12 -South Pointe Phase ll Project; Funding for the final payment to the Contractor is subject to the Srh Amendment to the Capital Budget for Fiscal Year 2013114 to be presented at the June 11,2014 Commission Meeting. ATTACHMENTS: Exhibit A - Horizon's Claim Letter Exhibit B - Horizon's Mediation Statement and Summary (Summary and Conclusion only) Exhibit C - Supplement to lnterim Settlement Agreement Exhibit D - Final Settlement Agreement Exhibit E - Summary of Horizon's Claim Settlement JLM/MTiDM/MS/CD T:\AGENDA\2014Uune\Horizon Construction Settlement Memo.doc 680 RECEI\trIERSON 8E ESPINO, P.A. MrcraELP.IErBsoN ^.. .t- r o ATTORNEIS AT LAv ALEIANDRoT*INo' t I ICI 26 f loatruslr**,* BBth Strcct. Suitc 220I*tH"o3*.--". ,.,r v aIT0RRLYs oFFtQfir-i rtorida 33176 ur r r "' ' TeI (30r 270iV3.Far(305)u3-7410 Exhibit DA\mI.I. I{ALLEY. P.E. Da,trEt I. MuNIrr.A MAr{ITEWMARA}IGEs October 25, 2011 lvfs. Rhouda Montoya-Hasan City ofMiami'Beach Office of thc CityAttomey 1700 Couvention Center Drive Miami Bcacl, FL 33139 RE: Cify of Miami Beach Right-of-Way Inf;a,1tructure trmprovemeot Program, Neighborhood 12 - SoutbPoiate RDA Phas€ tr Projecq Our File No.: 305-007 Dear Roude This fiflo reprcscnts Horizou Coutracbrs, Inc. C1lorizon") with rcgard to the above- referenced project- Horizon iDstr'uc'ted that we submit this denand for mediation to you in accordance wit} its contact with tbe City ofMiami Bcach (thc "Cit/). Pursuaot to Section 12, Resohrtiou ofDisputcs, Article 12.2 ofthe Geueral Coaditions of the pdae contact entercd by Hor.izon aad the City, Horizoa hereby demaods a mediation conf=encc to resolve tbe below contoversies or claimc irising orX of or rclating to the coutract or tbe b,reach thereof. The followiog claims oi cortroversies remain outstandiig, despite Horizoo's efforts to resolve tl.ese issues short of uediatioo. The clains or controversies to be mcdiated iaclude: ' Inability tir Acquire DERrV Tree Removil Permit - Horizou applieil for a tee renoval pe it with DERM. Howwer, DERM rejected the permit applicatiou becalse the City bad nurerous other such permits opea Addilion4lln the design docr:mcnb neeiled to bc modified to iaclude additional iaformatioa. Thc delay of approximately 70 days affected Horizon's wodr, inchrding clearing and grubbing operations. . Inability to Dewater - Horizou applied for a dewatcring permit with DERM. . [Iowever, DERM rejected the pemit applicatioa because of contamirated grormdwder. Via Elzctronic A AS Mail o The lac! of a dewatering permit required Horizon to install the r*ilities in the wet, inpacting the productivity of its crews, exleading the timc for such wodc, iocteasing the cost of such work and rcquiring additional work and effort to seal thpjoints of the pipe. 681 Mq. KIoEda Montoya-Hasatr October 25, 2011 Page 2 o Furthemore, &u'ing this scope of worlg Horizon discoverrd nunerous exisiing utilities that were not identitred in the plans, causing further disnrptions to its scope of work aad increased tirne and costs. o Additionally, Horizon incurred additional costs for testing and cleaning of the pipe. The City changed the testing criteri4 requiri:rg bay datum and testhg at high tide only, and also required the testing of a greater amornt of pipe. Such requirements were not included in the contract and/or required by indusbry standards aad practices. Tbe inability to dewater caused additiooal siltatioo and sedimentation to collect in the ptpe, thus increasing the cleaning costs for the Plpe. Unpaid Supplemental AgreemeutVChange Orders - [o late 2009, Horizon submitted a supplemental agreement/change order to the eo.gineer of record for unforeseen conditious, design errors and owler-rcquested modificatioos. Oo about Febnrary 10, 2010, the EOR recommended by letter that the City execute the change order, and the EOR itself exeqted the change order. It is Horizon's understarding that the City in fact executed the chaage order, but Horizoa bas oot been provided a copy of thc firlly cxecuted changc ord*. The partics had agreed r.rpou a value for the cha:rge onder, but since it was uot paid by the City, Horizon is scekiag thc fulI value of its orieinal Foposed change order of $103,981.19, plus iilerest. Revision #4 Chauge Order - Shortly after bid" the City revised the plans and specifi.cations, adding certain scope and reducing the scope of certain work Horizon submited a request for change order regardiog the additional costs associated with the revisions. The City uailaterally determineil tlat there were no additional costs associated with the rwision and rejected the change order. Horizon seels payment for the additional costs ioctmed. 4th Street Water Main Delay- Ilorizoa was impacted by delays/damages associated with the constant breakrge, repat, and ultioate replace'nreat of tbe wata main along 4s Streeq Aom Jefferson Court to \Mashington Avenue. Water Main Tie In/Shutrlown Delays - At the commencemert of the projec! the Public Works Departnreot requested and establish the procedures for requesting aod performing a water-main sleutdown. However, tlroughout the course of the project the City, padicularly the Public Works Deparheng change[_ those procedures from whnt was ori grnal lllestablished. Oo many occasions, the lack of timely response by the Public Worls resulted il Iong dclays. repetitive unnecessary work performed and costs to the project. Payment of Contract Balances & RetaiaagelDelays in Project Closeout - Horizon requested the release sf lsxoeiniig ret2inage via payment requisition 22 682 tvl$. fi.oonoa Mooloya- Har an Ootober 25, 201I on July 15, 2011. The EO& the City's project Eranager aad the City's senior project manager all approved the release of the remaining retainage. However, the City has failed aad refirsed to release the retainagg and Horizon has requested payfleDt of interest for its failure to pay. Horizoo has also incuaed additional o(penses as a result of the City's fiilre aad refisal to close the project Lastly, the City still owes Horizoa payment for coutract balances. . Finalize City's Desirc to Complete Laurlscaping and Irrigation Punchlist items due to the Cityrs Desire to Moilify Associrted Landrcaping and Irrigation Desigu - The City is$red final completion for all areas of work ercept for ccrtain landscapiog and irrigation items. The City indicated that it intended to modifr the design of certain lantlscaping aod irigatiou items on the project. Therefore, it deternj!.ed that it would seek a credit from llorizou for puncblist iteos associated with those areas, and the City would redesip and modi& those areas undq separate codracts. These issues need to be addressed and resolved so that the project canbc closed out. . Violation of Prompt Peyment Act - Throughout the course of the project the City failed to makc payneat in accortlance with the time requircmeots of the Prompt Papr.ent Acq thcreby incuning liabitity to Horizoo for itrtp.rest al 1.5% per month. Horizon previousiy requested meetings to eiscrxs these claims and contoversies. On several occasioas thesc issues have beeo discussed, and oa numerous occasiotxr the City has agreed that Horizca is entitled to additional comperuation for some of these claims and coatroversies. Horizon hopes that the City shares iu Horizou's desire to resolve these claios and controversies ernisably without ftre ueed for litigation. Horizon recommends that the parties retain oae of the following mediators: 1. John Freud of Mediation Solutions; . 2. BmceAlorander of Casey Cikli43. PeterBrandt of Ferencik LibanoffBraudq or . 4. MarkelAnizabalagaofK&AMediatioo With regerrl to tbc selection of mecliators, it is of primary importaoce to Horizon to scheduls mediation to occur within the trext sixty (60) days, Prior to mediatioo, Horizou will provide detailed information regard.ing each of the above issues, including its damages, which at this time are being reviewed and aoalped by a colskuction consulunl Horizon hopes that the Citi will embrace the mediatioo process with an open mintl and full considelation of Horizon's positioo on each of the issues ideotified above. Should the City fail to reryond to this demand for mediatioo withit ten (10) days, Horizoa will assr:me that the 683 rvrt. \rlvuuA rYlutrlr,rJa-taasall Odober 25, 20 I I Page 4 Ciry is not interested in mediation and that the City rvaives the mediation cotrdition precedeot founC in Section 12.2. 'We look fonrard to hearing &om you within the next ten (Jp) days. Horizon Contractors, Inc. 684 Exhibit B MEDIATION STATEMENT Right of Way lnfrastructure lmprovement Program Neighborhood 12- South Pointe RDA Phase ll City of Miami Beach 685 MEDIATION SUMMARY OVERVIEW On 10 December 2008, Horlzon Contracto6 lnc. ("Horizon") was awarded a contract with the City of l,Iiarni Beach ('City') for a project known as City of Miami Beach, South Pointe Phase ll lnfrastructure lmprovements. The contract amount rvas 57,683,901; and included a performance period of 577 Calendar Days. The project consists of site preparation, earthwork, demolition, storm dralnage, road aRd walkway paving, water, liBhtrn& plantin& lrrigation, and graphics. The project is located in the area bounded by Washington Avenue on the east, Alton Road on the west,2nd Street on the south, and 5th Street on the north, with the exception of 3rd Street, which was part of a previous Phase I Project The nature of the project required adequate preparation and planning on the part of the City prior to iB release for bid. The contract requires that the contractor "maintain water lorels below the bottom of exqa\ration in all work areas where groundwater occurc during excaMltion construction, backfilllng, and up to acceptance of the installation,' The indusion of this contract provision in the solicitatlon would require the CW to conduct a thorough pre-solicjtation site investigation to ensure that groundwater contamination was not an issue as a Miami Dade County Department of Envlronmental Resource Management (DERM) dewatering permit would be invotved. Additionalv, the proiect included planting which would also involve DERM as a tree permit vrould be required, Finally, prior to the release of the solicifdtion, the contrdct would requlre complete drawings that would include the Gty's desired scope and depict the location of existing utilitles and other items that would be in conflict with the work being installed by the contractor. Unfortunately, despite its prFbid representations indicating othenvlse, the City failed to identify groundwater contamination in the work area which would not allow Hori2on to perform dewatering operations and forcing Horizon to perform work tn the wef, a more costly and time consuming work process Pipe tes'ing criteria rvas also changed by the city, causing Horizon to test additional pipe and / ! I I ",1 I.i 686 {.:t 1 :.:J l,l.t -r"1 i.,.l :',1 ?1 :r.liJ FN!;!l a) il ,..t I "','J .ll IiiJ ,2,it 't ',i J ll-q.i .."i 1 irl i:1".1 j ..J *,j conduct the tests only at high tide. Moreover, the.Gty. rnalntained open permits that impacted Horilon's ability to obtain the requisite oERM tree permlt, causing project delarA. Adding to fie drawtngs issued to r;nro, n;it.'ii"i"., ,,: ;;::r;i./: Notice to Proceed (NTP) as well as a myrlad of unforeseen conditions and conflicts not deplcted in the Contract Documents affected Horizon in most every location ofthe project. & conflicts. Throughout its perfo nance of work under the contract, Horizon provided the Oty with notice of the dewatering lssues affecting the proiect, the pipe testing criterla changes and their heact, the 3tll1.. tree permit lssue, the scope change brought about by the Gty's revision of the Contract Drawings,.and.- the unforeseen conditions and conflicts not depicted ln the contract drawings. Horiron ,orgl,t';;' resolve these outstanding issues affecUng the projeG submitting timely requests for both ... r.; "..j i-.;.:..r, , compensatr'on and addiuonal contract tlme ln accordance with the contract documents. To date, these issues remain unresolved. On 25 October 2011,.Pursuant to Section 12, Resolution of Disputet Article . lrjJ, j nj aiiJ 12.2 of the General Conditions of the prime contrast entered by Horlzon and the City, Horizon ril:-!.rti demanded a mediation conference to resolve all outstandlng controversies or clalms arlslng out of or relating to the contract Through this Mediaton Surnmary Horizon submits supporting informatioi' relating to these issues in advance of the mediation conference to assist the Mediator and the City In its understanding ofthe merlts of Horluon's demand, This N4ediation Summary addresses the following five unresolved issues on the project: 1) Dewatering lmpacts 2) Pipe Testing Criteria Chq$T 3) DERM Tree Permit hpacts 4) Contract Drawing Changes, Unpaid Changes, Unforeseen Conditions ,l .) r';..] z I I t-.'4 687 :, i i, 5) Undisputed Retainage; Prompt Payment Act lnterest, Contract J: Balance. ',: 'ti(,te: TtE iaen6 identiled in Hottton\ medio 'on equest orc consofidoted intothe obovefNe cotegodes. f, lt ,^ Sections of the wlediation Summary include references to corespondence, applicable specification' ii sections, dally reports, change order requests, requests for lnformatlon (RFfs), drawings, photographs, :1:i, , zs well as the Project Schedule- since the Summary is document intense, the electronlc version ofthe :.,''J document includes "hyperlinks' ouflined in blue boxes that are directly linked to referenced items. : Slmultaneously depressing the 'AIt' key and the "teft arrow' key will return you to the previous view. I 'I , '..,' I ,t.:: l I ,.,,1 rI ll 1 t:l '- ttl l:l -r:1 :ll 5 688 CLAIM COSTSUMMARY 1) o€rvatering lmpacts ' 2) Pipe Testing Criteria Changes S 457,090.40 S 701,098.30 , 3) DERM Tree Permit Impacts S @,725-45 I) ql Contract Drawtng Changes & Unpaid Changes $ 179,296.95 ,flAUndisputedRetainage;PromptPaymentActlnterestS316,522.33 TorAL $ t,t2+731.44 50 689 I i :l I I ,; I,l i ,,t I Irl i irrl l.-l:l .,1 ir 1 ,il.l ti'-J irt,1 _l ,'.rli iI Conclusion The nature of the South Pointe proiect required adequate prepaEtion and planning on the part of the gty prior to its release for bid. Adequate prepaEtion would include proper investigation of posslble contaminants that could affect dewaterlnB operations. Adequate planning would include ensuring that all OERM tree permits were up to date and all utilities and possible conflicts ldentified on the contract drawings. Unfortunately the project was neither adequately prepared nor planned when lt was released for bid and awarded to Horizon. Throughout lts performancg Horlzon acted ln good faith as a reasonable and prudent contractor, mitigatin8 the CIVS exposure to damages, placing the Oty on Notlce, and diliSently proceeding with the contract work. Atthough some issues have been resohed such as the GVs desire to complete landscaping and ini8ation punchlist relating to modifled landscaping and inigation desiEn, the 5 major issues outlined ln this Mediation Statement remain unresolved. Through thls Mediatlon Statement and through the Mediatlon process, Horilon's intention is to provide the City with all the informa8on required so lt may make the right dedsion and brint thls mutually challenging proJect to an equitable conclusion. CLAIM COSTSUMMARY Contract Dravuinl Chanaes & 4s 27 690 Exhibit C STIPI'LEIUENT TO INTERIIVI SETTLEI\,IENT AGREEi\TENT .AND I\DJOURNMENT BET\ryEEN HORIZON CONTILA,CTOIIS, INC. ANI) TIIE CIl-}'OF T\IIAI}II BEACH, FLORIDA This Supplenrent lo Interim Sctllenrent Agreetnent and Adjoumment ("Agreenrenl") is rnade ancl entered into this 24 da;' of .ilrif 2012. b1, and bcrrvcen HOt(lZoN CONI'RAC'IORS, INC., a Florida corporation. (hereinafier "Florizon") and the CITY OF N'llAN'll BEACH, FLORIDA. a nrunicipal corporation (hereinalier. the "Cit)''). Horizon aud the Citl rnal also be relbrred to individualli as a ''Part1'". and collectivel; rs the "Parries." RECITALS IYIIEREAS. HONZOT.N and the CITY are parties to a conslruction coutract. dated Decenrher 10,2009 (the "Contract"). forNeighborhood 12- South Pointe RDA Phase II, Miami Bcach. Florida (lrereinafter. the "Project"): and \YHIREAS, Horizon assened clairns for additional conrpensation and linre against the Citl' regarding multiple issues regarding thc construction ofthe Project: and \\'HEREAS. as required bv the Contract. the Pa(ies attended pre-suit nrediation on January' 6, 2012 (lhe "Mediation"l. resulting irr the execulion b1.. the Parties of an Interinr Settlemel)l Agreenrent and Adiournrnenl (the "Interinr Settlenrent Agreement"). a copl' ol rvhiclr is incorporated herein and is attached as Exhibir "A"; \YHERE.A.S, the Partlcs attcnded a seltlement conference on lr,tarch 5. 2012. to discuss thc leuraining clainrs and open issues related to the Project; $IIEREAS, the l'arlies cxecute this Agreenrent lo resol\.e certain clairns and disputes rvhile preserving other clainrs and disputes for litigation; NOW TIIEREFORE. in cousideration for the exclrangc of prourises containcd herein, and lor good and valuablc cousidcration acknorvledged herein. the Parties agree as follorvs: l. The above Recitals are true and corrcct and arc irrcorponrtcd herein. "t,h#uaot,,,flertcr{d 691 s('PPLr.lIE',i I O I\TEP,I.\t SeT .EjtF"v 7',lC/ll!',1/1"':\',7 <r ..tLUot ltlitE,Yl BL7'trLE\ ITORI'/,()\ (:O\1'R+C1'ORS /.\r & CJr/tl l. I'he tiitl' agrees lo pat the lollorving ilerns on or hclbrc March 20.3012 (thc "Contract Payments" ): a. I'}CO#6 Supplenrental 288-A. 288-BC. in lhe anrounl o15i70,079.96: b, Pal Applioation #25. rvhich includes itcnr a. above and Retainage in the anrount of $207,27?..64, for a total pa),nrcnt ol$277,352.60 3. I{orizon shall plovide all Final lien releases fronr its subcontractors and nraterial suppliers to thc Cit) and lulfill all otlrcl coulractual requil'enrerlts for the final Retainagc Release in the alrount ol 5100.000.00. Horvever, the Parties agree that the Contract Pa1'ments and associated lien releases in no u'al.release the Citt, from anl claims for additional compensation and tiure asserted br'l-lorizon and subnritted for lvlediation and thal such claims are presen'ed for litigation. including the follou'ing: a. b. c. d. Dcrvatering Lnpacts; Pipc 'l'csting Criteria Changes: DERM Trcc Pernrit lnrpacts: aud Contract Drawiug Changes. 4. Tlre Parlies agree to cooperate fulli and execute anl and all supplementarl' docurnents and to take all additional actions rvhich nral be reasonabll' necessarS, or appropriate to give full folce and effect to the basis and intent of this Agreement. -i. Il is understood and agreed that execr.rtion of this Agreernenl is not an cxpress or irnplied adnrission ofnegligence. misconduct. responsibilitl' or liabilitl' on lhe part of the Cit1, or Horizon. 6. Ilorizon agrees that it renrains lesponsible lbr any latent defects on the Proicct and all applicable u'aranties pulsuant to the tcrnrs of thc Contract aud Florida larv. 7. l'hc l)artics agree to declare the N,tediation ar an inrpasse. 692 ,,n,,,,!'ll/l;til#,rIIl'i#,l,ii#lii!;Y,l"f itill%;: 8. 'l'lris Agrecnrcnt contains the entire agreenrent belrveen the Parties regarding the clainrs raised at Ir4edi:rtion. This lgrccrnuut rcplaccs arrl prior or contctnporaucous rvrittcn or oral rcprescntation or understanding alrout the rernrs ol this Agreentent. This Agreenrenl ma) not bc changcd cxcept in uliting signed bl the Parties or their rcspeetive attorneys. This Agreenrcnl shatl be binding on and shall inurc to the benefit of thc respective successors and assi-rns. il an1'. o[ cach partr'. 9. This Agrccmcnt is being consurnnratcd in thc Statc of Florida. ancl tlrc perfbrntance b1, the Parlies hereto is in the State ol Florida. 'l'his Asreement shall be governed bl aud consuued in accordance rvith the larvs of the State o[ Florida. Thc vcnue for an1' legal procccding of anl Dature brought bl eirher parr,v against the othcr to enlbrcc an1, right or obligation uuder this Agreement. or arising our of anJ'matter pertaining to this Agreenrent, shall be in li,liami-Dade Countr.. Florida. 10. The I'arties \\'arrant to each other that the), have read this Agreement. lhat the)' underslaud this Agreenrent and that eaclr have been represented bv counsel belbre signing this A-rreerneut, IN Utll'NESS \\'llEREOt. the Parries havc set thcir hands and seais on tlre dav aud clate tirst rvritlcrr abovc- Ho B)': N CONTRA Attcst: Title: Q,-z- 693 SL P P LE,IIE}iT O I,\'TERI.V SEN' LE,II ENI' AG REE.II EXI' & .1 DJO L, Rv T I E \ T B ET'I'' E E i\ H O R I ZO I' C'CI.\T&{ CI.O&X I )i C & C.I I B STATE OF FLOzuDA COLINTY OF IVTIAIVII-DADE The foregoing instrument Print Name STATE OF FLORTDA COUNTY OF lvllAMI-DADE 20t1 personally kno*n identit'ication). ) )ss ) rvas acknowledged rvho has produced before me this -tlSaay of.Vlarch 2012,by V',o o-- P..-slD*ol Horizon is personally known to me or who has produced (type of identifi cation). My Commission Expires: lo - tE-- rE Aftest:W DAriL t4lr&'t, t}iL. ) )ss ) The_foregoing rvas pcknorvledged before me this 3'Q' aul' o1 ,/u-< A r! J/.za-a4.r Beach, rvho ts of(type APPRO/EDASTO FORM & LANGUAGE TFOREXECUTION ,l- a\6lL G,E,;Ig- - Notary Public - State of Florida (Print Name) Irll Ctrrnmission Eripires: Ct- 3t - 3t" i{ 694 In Re: Horizon Cont.ractors , CIaimanL, City of Miami Beach, Inc . , Respondent. The parties and./or counsel, witsh fuII authoritsy, agree t.o settlemeDt of the abowe referenced matstser and conditions : in'ler;'n SETTIJE!.IENT AGREEME!f,I j A,/j oararnen r voluntarily consent and upon the following t.erms r-. within t/ *", RespondenE (s) shall pay Claimant (s) the toti- amourrt "t.* -r+ - zg?'L check(s) made payable and dblivered to claimant (s)' as follows I Lt/- l7e)t) 4 Each party and/ or tsheir counsel- shall pay thei-r share of the tttediation fees and costs. The Court. shal1 reLain jurisdiction to enforce the terms of this setstslement/ including enforcements of Che palment of med.iation fees and costs. Courrsel for Claimant (s) g. /// o tArr I /a ;*'J / i6o,ss; sa /nfll im 2attt o/ lrrt at'aia7 2r,,{iV fo, {'rlAer P sa /,,1 to ^ /sr ?ilr,ry a f(. . agreement / satis fact.ion or re!liens of any related to,, tshe subject maLtser of Lhe insand, a voluntary dismissal of aIl- cl-ai-ms, wi 695 \Di\i.{r\\$s$ir\'/^l-l{$I$f-\l\-ld\Ni696 City of Miami Beach, South Pointe, PH llsupplemental CO Breakdown with lnterest calculations01.11.2012Netotiated $s 7,635.895 8,4LL.76S 9,1r.8.1s5 3,440.4ss 23,653.19S 8,78s.s4s 5r,054.96SupplementalA-FSupplementalG-RSupplemental s-ADSupplemental AE-AFSupplemental AG-ASsupplemental AT-BCBase CO Amount:lneterestYear 1:lnte rest Year 2:Part. lnterest Year 3:Submitted(Used City Date on CO)0slL6/2OO907 /0e/200908112/200908/ 17l20o909/7712OO9r0lL6|2OO9To be Paid By(30 Doys Later)06/Ls/200908/08/200909lfil2Oo909/16/2009to/L7l2OO9t7lLsl2009sss$s51,054.957,326.608,705.792,939.L279,s26.46lnterestYear 1 I lnterest Year 2 | Part. lnterest Year 3(through 2070) | (throush 2017) | (tbrough Janudry ZO72)s 915.31 06/1sl2010 | S r,026.26 o6hs/2ol7l 5 670.4ss 1,009.41 08/08/2010 ls 1,130.s4 08/08/20111 s s27,s9s 1,094.18 09/xu2010 I sL,22s,48 09/1712OL1,1 5457.5r09/15/2010 | s$ 412.8s 09/15/2010 | S 462.40 oe/r6l2}LLl g r72.6ss 2,83e.s8 70177/2070 | $ 3,780.33 to/L7lzOLLl g 8e0.49$ 1,0s4.26 rl/7s12010 ls 1,180.78 r1l1sl2o11lS 220.4r7697 Exhibit D SETTLEMENT AGREEMENT AND MUTUAL RELEASE BETWEEN HORIZON CONTRACTORS.INC. AND THE CITY OF MIAMI BEACH. FLORIDA This Settlement Ageement and Mutual Release ("Agreement") is made and entered into this _ day of _,2014, by and between HORIZON CONTRACTORS, INC., a Florida corporation, (hereinafter "Horizon") and the CITY OF MIAMI BEACH, FLORIDA, a political sub-division of the State of Florida (hereinafter, the "City"). Horizon and the City may also be referred to individually as a "Party," and collectively as the '?arties." RECITALS WHEREAS, Horizon and the City are parties to a construction contract, dated December 10, 2009 (the "Contract"), for Neighborhood l2-South Pointe RDA Phase II, located in Miami Beach, Florida (hereinafter, the "Project"); WHEREAS, Horizon asserted claims for additional compensation and time against the City pertaining to the Project; WHEREAS, as required by the Contract, the Parties attended pre-suit mediation on January 6, 2012 (the "Mediation"), resulting in the execution by the Parties of an Interim Settlement Agreement and Adjoumment (the "lnterim Settlement Agreement"), a copy of which is incorporated herein and is attached hereto as Exhibit "A;" WIIEREAS, the Parties attended settlement conferences on March 5, 2012, and March 20,2014, respectively, to discuss the remaining claims and open issues related to the Project; WHEREAS, the Parties desire to settle all claims, disputes, past, presenl, or future regarding the Project. regardless ofresponsibility; and WHEREAS, the Parties believe it would be in their best interests and the best interests of the citizens of the City to agree to the provisions of this Agreement. NOW THEREFORE, in consideration for the exchange of promises contained herein, and for other good and valuable consideration, the receipt and suffrciency of which are hereby acknowledged by the Parties, the Parties agree as follows: I . Recitals: The above Recitals are true and correct and are incorporated herein. 2. Settlement: The Parties hereby settle and compromise all claims of any kind or nature (including any claims for attomey's fees and costs), relating to, arising out of and/or in connection with the Project, except as set forth herein. 698 3. Settlement Terms: In consideration for the releases executed herein, the Parties agree as follows: (a) The City agrees to pay Horizon the sum of Four Hundred Ninety Thousand Dollars and 00/100 ($490,000.00) (the "Final Payment"). (b) The City will seek to place this item on the Agenda for the City Commission Meeting following the approval of the Agreement in form and correctness by the City Attomey. (c) Subject to the City Commission's approval of this Agreement, the Final Payment shall be made by the City within thirty (30) days following City Commission approval and execution by the City of the associated Resolution approving such settlement. (d) As a condition precedent to the City's Final Payment, Horizon shall fumish to the City, for review and approval, digital copies of the Water Main, Storm Water Drainage and Electrical as-built drawings for the Project, in pdf format and in the latest version of CAD. Horizon shall also submit to the City, for review and approval, 11" x 17" paper copies of the Water Main and Storm Water Drainage as-built drawings for the Project, signed and sealed by a Florida- licensed Professional Land Surveyor. 4. Releases: In further consideration of the execution of this Agreement, the Parties for themselves and their respective parent compmies, subsidiaries, divisions, affiliates, unit owners, insurers, officers, directors. agents, employees, subcontractors, representatives, successors and assigns (the "City Releasors" or "Horizon Releasors" as the case may be), hereby execute, subject to the conditions and exclusions set forth in this Agreement, the following Releases: (a) Horizon Releasors' Release of Cit), Releasors: Upon payment of the Final Payment by the City, the Horizon Releasors hereby remise, release, acquit, satisfy and forever discharge the City Releasors, which throughout this Agreement includes, but is not limited to, its affrliates, Commissioners, insurers, sureties, directors, officers, employees, agents and attorneys, together with its heirs, executors, administrators, associates, representatives, successors and assigrs, of and from any and all manner of past, present and future claims, action and actions, suits, debts, dues, sums of money, accounts, reckonings, bonds, bills, specialties, covenants, contracts, controversies, agreements, promises, variances, trespasses, obligations, damages, judgments, costs, expenses, cause and causes of action, executions, claims, liabilities, and demands whatsoever, in law or in equity, 699 whether for compensatory, punitive, or other damages (collectively referred to in this Paragraph as the "Claims"), which the Horizon Releasors have held or now hold, ever had, now have, or which the Horizon Releasors, hereinafter can, shall or may have against the City Releasors, for any and all Claims, whether known or unknown, arising from, pertaining to and/or in any way relating to the Project. (b) City Releasors' Release of Horizon Releasors: Except as provided and expressly subject to the limitations set forth in Paragraph 5 herein, which the Parties agree and acknowledge limits the scope of the City Releasors' release ofthe Horizon Releasors, the City Releasors hereby remise, release, acquit, satisry and forever discharge the Horizon Releasors, which throughout this Agreement includes, but is not limited to, its affiliates, insurers, sureties, directors, officers, employees, agents and attomeys, together with its heirs, executors, administrators, associates, representatives, successors and assigns, of and from any and all manner of past, present and future claims, action and actions, suits, debts, dues, sums of money, accounts, reckonings, bonds, bills, specialties, covenants, contracts, controversies, agreements, promises, variances, trespasses, obligations, damages, judgments, costs, expenses, cause and causes of action, executions, claims and liabilities, and demands whatsoever, in law or in equity, whether for compensatory, punitive, or other damages (collectively referred to in this Paragraph as the "Claims"), which the City Releasors have held or now hold, ever had, now have, or which the City Releasors, hereinafter can, shall or may have against the Horizon Releasors, for any and all Claims, whether known or unknown, arising from, pertaining to and/or in any way relating to the Project. 5. Latent Defects and Warranties: (a) The Parties agree that, specifically excluded from any release or waiver by the Parties under this Agreement, are any demands, claims and causes of action arising from: (i) latent defects; (ii) warranty claims; or (iii) any third party actions for property damage, bodily injury, personal injury or death pertaining to the Project. The City shall not be precluded from bringing any action at law or equity arising from or relating to such matters. (b) Horizon agrees that it shall honor and be responsible to the City for all warranties and guarantees as specified in the Contract and/or as otherwise provided by law or in equity. Horizon further acknowledges and agrees that nothing contained in this Agreement shall constitute a waiver of any right by the City to seek enforcement of those warranties and guarantees against Horizon, its sureties, insurers, subcontractors and suppliers. 6. No Admission of Liabilitv: It is understood and agreed that the claims which are the subject of this Agreement are disputed claims and that the execution of this Agreement by the Parties, and the exclusions set forth in this Agreement, are not intended to, and shall not in any 700 way, constitute or be deemed an express or implied admission or acceptance of any negligence, misconduct, responsibility or liability by the Parties or an admission against interest by the Parties, and that the Parties expressly and specifically deny all such claims. Such consideration is being given to reduce the expense, uncertainties and hazards of litigation and to mitigate damages to each of the Parties. There shall not be any implication by any trier of fact or law of any admission or acceptance of liability or admission against interest by the Parties and it shall not be used against the City Releasors or the Horizon Releasors in any attempt to prove any futrue liability claims. 7. Binding Effect: Subject to City Commission approval and execution by the Parties, this Agreement shall be binding upon the Parties and their respective successors and assigns. However, execution and notarization by all Parties shall be a condition precedent to the effectiveness of this Agreement as binding against any Party. If the City Commission does not issue the approval, the Agreement shall be null and void and of no force and effect. 8. Attomey's Fees: If any legal action, proceeding, or hearing is brought by the City Releasors or the Horizon Releasors to resolve a dispute regarding enforcement of the terms of this Agreement, then the prevailing party as between the City Releasors and the Horizon Releasors shall be entitled to recover reasonable attorney's fees and court costs incurred. The Parties shall bear their own fees and costs relating to the negotiation and execution of this Agreement to date. 9. Miscellaneous: The Parties further agree as follows: (a) The Parties acknowledge and agree that this Agreement is fully and adequately supported by consideration and is fair and reasonable. The Parties further acknowledge and agree that: (i) each Party has had the opportunity to consult with, and has in fact consulted with, such professionals, experts and legal counsel of its choice as such Pany may have desired with respect to all matters settled and resolved herein; (ii) each Party has participated fully in the negotiation and preparation of this Agreement; (iii) each Party has carefully reviewed this Agreement and is entering into same freely; and (iv) this Agreement is entered into in good faith and was not obtained by fraud, misrepresentation, or deceit. Accordingly, this Agreement shall not be more strictly construed against any Party. (b) The Parties hereto understand and agree that this Agreement will not be binding on the Parties to this Agreement until such time as the City Commission of the City of Miami Beach has approved same, and the Agreement is fully executed by the Parties to the Agreement. City Commission approval is a 701 material condition precedent to the execution and enforceability of this Agreement, without which the City does not agree to, and is not subject to, the terms and conditions contained herein. (c) Each of the signatories hereto represents that he or she has authority to execute this Agreement and to bind the Party on whose behalf he or she has signed. (d) This Agreement is being consummated in the State of Florida, and the performance by the Parties hereto is in the State of Florida. This Agreement shall be construed and govemed in accordance with the laws of the State of Florida and the sole and exclusive venue for any lawsuit relating to this Agreement is Miami- Dade County, Florida. The Parties expressly agree to waive trial by jury in any action to enforce this Agreement. (e) In construing this Agreement, the singular shall be held to include the plural, the plural shall be held to include the singular, the use ofany gender shall be held to include every other and all genders, and captions and paragraph headings shall be disregarded. (0 Any exhibits attached to this Agreement are incorporated in, and made a part of. this Agreement. (g) Time is of the essence in the performance of this Agreement. 10. Entire Agreement: This Agreement, together with any documents referenced herein, constitutes the full and entire agreement and understanding between the Parties as related to the Project, and there €ue no agreements, representations or warranties except as specifically set forth herein. This Agreement replaces any prior or contemporaneous written or oral representation or understanding about the terms of this Agreement. All prior discussions, negotiations, Ietters, demands and writings of any kind are fully merged into this Agreement and are to be construed to be ofno further force or effect, it being the intention ofthe Parties that this Agreement shall serve as the sole and entire expression of their agreement and understanding. This Agreement shall be binding on, and shall inure to the benefit of the respective successors and assigns, ifany, ofeach Party. ll. Modificationl No Waiver: This Agreement may only be modified in writing signed by both Parties. No waiver or modification of the Agreement or of any covenant, condition or limitation contained herein, shall be valid unless in writing and signed by all Parties to the Agreement, or their authorized counsel. If the City or Horizon excuses or condones any 702 breach or default by the other Party of any obligation under this Agreement, this shall not be a waiver of such obligation with respect to any continuing obligation or subsequent breach or default and no such waiver shall be implied. 12. Counterpafis: This Agreement may be executed in one or more counterparts, each of which shall be deemed an original, but all of which together represent one instrument binding on the Parties, notwithstanding that all of the Parties are not signatories to the same counterpart. The Parties further agee that this Agreement may be signed and submitted via facsimile or electronic mail. 13. Severabilitv: If any provision of this Agreement is held or rendered illegal or unenforceable, it shall be considered separate and severable from this Agreement and the remaining provisions of this Agreement shall remain in full force and effect and bind the Parties as though the illegal or unenforceable provision had never been included in the Agreement. 14. Captions: References: The captions of this Agreement are for the purpose of convenience of reference only and in no way define, limit or describe the scope or intent of the Agreement or in any way affect the terms and conditions of this Agreement. A11 references in the Agreement to the terms "herein," "hereunder," "hereof' and words of similar import shall refer to this Agreement, as distinguished from the Paragraph, Section and/or Subsection within which such term is located. 15. Third Parties: Nothing express or implied in this Agreement is intended or should be construed to confer upon or give any person or entity, other than the City and Horizon, any rights or remedies under, or by reason of, this Agreement. IN WITNESS WHEREOF, the Parties have set their hands and seals on the dav and date first written above: lRemainder of page intentionally left blank.) 703 HORIZON CONTRACTORS, INC. Attest: Jose M. Sanchez, President Secretary Print Name STATE OF FLORIDA COUNTY OF MIAMI-DADE The foregoing instrument was acknowledged before me this _ day of _, 2014,by Jose M. Sanchez as President of Horizon Contractors, Inc., who is personally known to me or who has produced (type of identification). Name: (Print Name) Notary Public - State of Florida My Commission Expires: 704 ATTEST: City Clerk SEAL APPROVED AS TO FORM AND CORRECTNESS: City Attomey THE CITY OF MIAMI BEACH, FLORIDA, a Municipal Corporation of the State of Florida Print Name: Title: APPHOVED AS TO FORM & LANGUAGE & FOII EXEGUTION By: 705 Exhibit EaMIAMIBEACHExhibit E- Summarv of Horizon's Claim SettlementCLAIM DESCRIPTIONDewatering lmpactsPipe Testing Criteria ChangesDER[4 Tree Permit lmpactsConlract Drawing Changes, Unpaid Changes, Unforeseen Conditions & Conflicts.Undisputed Retainage; Prompt Payment Act lnterest, Contract Balance.TOTALSORIGINALCLAIMA OUNT$467,090.40$701,098.30$60,725.45$179,296.94APRIL 2OI3SETTLEMENTAGREEi,IENT$189,871.00$264,294.00$35,835.00706 RESOLUTION TO BE SUBMITTED 707