HomeMy WebLinkAboutPardee Homes Cooperative Agreement 10-01-15 COOPERATION AGREEMENT
This COOPERATION AGREEMENT ("Agreement") is made and effective as of the 1st
day of October, 2015 ("Effective Date"), by and among the CITY OF LAKE ELSINORE, a
California Municipal Corporation ("City"), on the one hand, and PARDEE HOMES, a California
Corporation ("Pardee"), on the other hand(collectively, "Parties", and individually, "Party").
RECITALS
WHEREAS, the Western Riverside Council of Governments ("WRCOG") has
commenced enforcement proceedings and investigations (the "Action") against the City in
connection with a dispute over the City's collection of Transportation Uniform Mitigation Fees
("TUMF') related to development occurring within the Cottonwood Hills (aka Canyon Hills)
Specific Plan area as designated in the July 9, 1990, development agreement with Pardee-
Grossman/ Cottonwood Canyon, a general partnership organized and existing under the laws of
the State of California, including all amendments and any Memorandums of Understanding
thereto (the "Pardee Agreement"). Pardee, Richmond American Homes of Maryland, Inc., a
Maryland corporation, and Pulte Home Corporation, a Michigan corporation, are the current
successors in interest to the Pardee Agreement and developers within the Canyon Hills Specific
Plan area defined therein.
WHEREAS, the above-referenced enforcement proceeding and investigation has resulted
in the City having to consent to that certain Memorandum of Agreement ("MOA") in which City
and WRCOG will engage in a voluntary non-binding arbitration (the "Arbitration"). Pardee is
neither a party to the MOA nor the Arbitration and is not bound by nor involved in either. The
MOA, among other things, provides that at the conclusion of the non-binding arbitration, either
the City or WRCOG may elect to file an action in Superior Court seeking a declaration, among
other things, as to whether the development occurring within the Cottonwood Hills (aka Canyon
Hills) Specific Plan area is exempt from TUMF (the "Future Litigation"). Because Pardee's
project, a residential development project (the "Project"), is in the Canyon Hills development,
Pardee is an interested parry in such Future Litigation.
WHEREAS, WRCOG asserts that the City owes past due TUMF relating to building
permits issued by the City in connection with the Project. The City and Pardee dispute
WRCOG's position and maintain that no such TUMF are due in connection with past or future
Project building permits.
WHEREAS, the Parties and their respective attorneys of record entered into that certain
joint defense agreement (the "Joint Defense Agreement"), dated July 15, 2015, under which the
Parties agreed to, among other things, share information with respect to their defenses of the
Action and Future Litigation.
WHEREAS, the Parties now wish to resolve various uncertainties related to the outcome
of the Action, Arbitration and Future Litigation. This Agreement sets forth the allocation of
TUMF responsibility among the Parties, depending on the outcome of the Action, Arbitration or
Future Litigation.
- 1 -
AGREEMENT
Based upon the foregoing recitals, which are true and correct and incorporated herein by
reference, and in consideration of the mutual promises of the Parties, it is hereby agreed as
follows:
1. The City's Responsibility for Past Due TUMF. The City agrees that if a
determination is reached in favor of WRCOG in the Action, Arbitration, Future Litigation,
settlement, TUMF Recovery Litigation (defined below), or otherwise, in whole or in part, the
City shall be solely responsible for the payment of any and all TUMF alleged by WRCOG to be
due from the 2003 effective date of the TUMF through the Effective Date of this Agreement
("Past Due TUMF"). The City further agrees that regardless of the outcome of the Action,
Arbitration or Future Litigation, Pardee shall not be responsible for the payment of any Past Due
TUMF.
2. Pardee's Responsibility for Future TUMF. From and after the Effective Date
of this Agreement, the Parties agree that the City will be permitted to collect TUMF for building
permits issued thereafter in connection with the Project ("Future TUMF"). The Parties
acknowledge that Pardee will tender such Future TUMF under protest, and that Pardee will
institute proceedings against the City and WRCOG to recover such payments, plus statutory
interest under Government Code section 66020, subdivision (e) (the "TUMF Recovery
Litigation"). If a final determination is reached in favor of WRCOG, in whole or in part, in the
Future Litigation, TUMF Recovery Litigation, or other action, and provided that Pardee is a
party to any such Future Litigation, TUMF Recovery Litigation, or other action, Pardee shall be
solely responsible for the payment of any and all Future TUMF awarded to WRCOG. Pardee
further agrees that regardless of the outcome of the Action, Arbitration, Future Litigation, or
TUMF Recovery Litigation, City shall not be responsible for the payment of any Future TUMF.
Pardee expressly reserves and does not waive or release any rights to assert any claims, defenses,
interests, or causes of action in the Future Litigation, TUMF Recovery Litigation, or other action,
including, but not limited to, breach of contract, interference with contract and impairment of
contract claims. Notwithstanding the foregoing, Pardee agrees that it will seek to collect and
enforce first against WRCOG any judgment obtained in Pardee's favor in the Future Litigation,
TUMF Recovery Litigation, or other action, including recovery of TUMF tendered under protest
and statutory interest relating thereto. Pardee also agrees that it will not collect and enforce
against the City any judgment it obtains in the Future Litigation, TUMF Recovery Litigation, or
other action, other than recovery of TUMF tendered under protest.
3. Confidentiality of this Agreement. This Agreement shall be privileged from
discovery and inadmissible as evidence in any legal proceedings brought against the Parties or
any of them and this Agreement shall not be disclosed to any Third Party except where necessary
to enforce the terms of this Agreement or to comply with a court order.
4. No Admission of Liability or Waiver. This Agreement is not an admission of
liability or fault of any Party in reference to any alleged or asserted facts, legal contentions and
occurrences that are now or might be alleged with respect to any threatened or asserted claims
associated with or in any way related to the Action, Arbitration or Future Litigation. Neither this
Agreement, nor any information contained in or submitted under this Agreement, nor any action
-2 -
taken by any Party pursuant to this Agreement shall constitute, be interpreted, construed, or used
as evidence of any admission of liability, law, or fact, waiver of any right or defense, nor as an
estoppel, against any Party by any other Party or by any Third Party. The Parties further
acknowledge that all communications between the Parties concerning the Action, Arbitration or
Future Litigation shall be considered settlement discussions protected under California Evidence
Code section 1152, except for public meetings and/or public documents regarding the Action,
Arbitration, or Future Litigation.
5. No Third Party Beneficiary. Except as specifically provided herein, nothing in
this Agreement shall waive, release, or otherwise affect any right, claim, defense, interest, or
cause of action that any Party may have with respect to any Third Party. This Agreement is not
intended for the benefit of any Third Party and shall not be enforceable by any party who is not a
Party.
6. No Joint Venture. This Agreement does not form a joint venture or
partnership by or among the Parties.
7. Amendment. No part of this Agreement may be modified, altered, amended,
waived, or changed without the express written consent of the Parties hereto.
8. Notice. All notices under this Agreement must be in writing. Notice is given
either (i) when delivered in person to the person or company intended named below, or (ii) when
sent via reputable overnight courier (such as Federal Express), addressed by name and addressed
to the party or persons intended, as follows, until such time as a party gives notice of a change of
address in accordance with the terms of this section:
Pardee Citv
Attn: Christopher J. Hallman, Attn: City Manager
General Counsel, Pardee Homes Lake Elsinore City Hall
c/o TRI Pointe Group 130 South Main Street
19450 Jamboree Road, Ste. 300 Lake Elsinore, CA 92530
Irvine, CA 92612 Phone: (951) 674-3124
Phone: (949) 438.1451 Fax: (951) 674-2392
Fax: (949) 438-1401
Mike Taylor, Division President
Inland Empire/Orange County
35050 Canyon Hills Road
Lake Elsinore, CA 92532
Phone: (951) 246-2218
Fax: (951) 246-2155
-3 -
With a copy to: With a cony to:
Attn: Michael L. Tidus, Esq. Attn: Barbara Leibold, Esq.
Jackson, DeMarco, Tidus & Leibold, McClendon & Mann, APC
Peckenpaugh, APC 9841 Irvine Center Drive, Suite 230
2030 Main Street, Ste. 1200 Irvine, CA 92618
Irvine, CA 92614 Phone: (949) 585-6300
Phone: (949) 752-8585 Fax: (949) 585-6305
Fax: (949) 752-0597
9. Assignment. This Agreement shall not be assigned by either Party, either in
whole or in part, without the prior written consent of the non-assigning Party. Any assignment
or purported assignment of this Agreement without the prior written consent of the non-assigning
Party will be deemed void and of no force or effect.
10. Interpretation. The Parties hereto have negotiated this Agreement at arm's
length and have been advised by their respective attorneys, and no provision contained herein
shall be construed against any Party.
11. Authority to Execute. The individuals executing this Agreement each represent
and warrant that they have the legal power, right and actual authority to bind their respective
Parties to the terms and conditions hereof.
12. Counterparts. The Parties may execute duplicate originals (counterparts) of the
Agreement or any other documents that they are required to sign or furnish pursuant to the
Agreement.
13. Severability. If any provision of this Agreement is found invalid or
unenforceable,the balance of this Agreement shall remain in full force and effect.
14. Term. This Agreement shall terminate as to all Parties on the date on which the
later of the following events occurs: entry of final judgment in the Action and any Future
Litigation and any TUMF Recovery Litigation; dismissal of all causes of action as to all Parties
in the Action and any Future Litigation and TUMF Recovery Litigation; settlement of the Action
and any Future Litigation and TUMF Recovery Litigation as to each and every Party; and
completion of all payments by the City to WRCOG as required under this Agreement (the
"Termination Date"). Any Party may terminate this Agreement effective upon written notice of
termination to all other Parties. After termination, the Parties shall continue to preserve the
confidentiality of this Agreement, the Joint Defense Agreement, and all Defense Materials under
the Joint Defense Agreement, in the manner set forth herein.
15. Entire Agreement. No other agreements, express or implied, have been made by
the parties to this Agreement concerning the subject matter herein, other than the Joint Defense
Agreement. All prior and contemporaneous conversations, negotiations and possible or alleged
agreements concerning the subject matter herein are merged and integrated in this Agreement.
-4 -
IN WITNESS WHEREOF,the Parties have executed this Agreement as of the Effective Date.
CITY OF LAKE ELSINORE PARDEE HOMES
a California Municipal Corporation a California Corporation
By: Grant Yates By: Mike Taylor
City Manager Division President
ATTEST: APPROVED AS TO FORM:
By: Susan Domen Christopher J. Hallman
City Clerk General Counsel
APPROVED AS TO FORM:
LEIBOLD McCLENDON & MANN, PC
By: Barbara Leibold, City Attorney
- 5 -
IN WITNESS WHEREOF, the Parties have executed this Agreement as of the Effective Date.
CITY OF LAKE ELSINORE PARDEE HOMES
a California Municipal Corporation a California Corporation
l
By: Gr ates By: Mike Taylor
City M4dager Division President
ATTEST: APPROVED AS TO FORM:
Gt/J
By: SuAailDomen sto a man �$/ �0
City Clerk General unsel
APPROVED AS TO FORM.-,
db"L- 7 ) -
LL4BOLD McCLENDON& MANN, PC
By: Barbara Leibold, City Attorney
- 5 -