HomeMy WebLinkAboutCC RESO 15,287RESOLUTION NO. 15,287
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF NATIONAL CITY
AUTHORIZING THE CITY MANAGER TO EXECUTE AN AGREEMENT WITH
ARTHUR L. CARVER, BRUCE A. CARVER, SUSAN E. CARVER,
AND RANDALL B. CARVER
BE IT RESOLVED by the City Council of the City of National
City that the City Manager is authorized to execute an agreement
between the City of National City and Arthur R. Carver, Bruce A.
Carver, Susan E. Carver, and Randall B. Carver, providing for pay-
ment to the City of $50,000 by May 8, 1987, and 103 monthly
installment payments of $1,000.36 beginning May 1, 1987.
PASSED and ADOPTED this 28th day of April, 1987.
eor Waters, Mayor
ATTEST:
Ion= Campbell, Ci/ Clerk
APPROVED AS TO FORM:
George H. Eiser, III -City Attorney
AGREEMENT
THIS AGREEMENT is made and entered into between the CITY OF
NATIONAL CITY (hereinafter "CITY"), and ARTHUR L. CARVER, BRUCE
A. CARVER, SUSAN E. CARVER and RANDALL B. CARVER (hereinafter
"CARVERS").
This Agreement is made with reference to the following
recitals:
A. On May 17, 1982, a judgment was entered in San Diego
Superior Court, Action No. 427262, in favor of CITY against the
Carver Corporation and American Fidelity Fire Insurance Company
in the sum of $98,180.16, plus interest, and for costs in the sum
of $1,078.44 (the "Judgment"). The Carver Corporation appealed
from said Judgment, and in order to stay execution of the
Judgment pending appeal, undertakings were filed by CARVERS, as
sureties. Said undertakings provide that CARVERS will pay the
amount directed to be paid by the Judgment appealed from, and
that if CARVERS do not make such payment within 30 days from the
filing of the remittitur, on motion of CITY, judgment may be
entered in favor of CITY against CARVERS.
B. The appeal of the Carver Corporation was dismissed on
April 22, 1983, and a remittitur filed in the Superior Court on
June 22, 1983. The Judgment was not paid within 30 days of the
filing of the remittitur in Superior Court. On may 29, 1986,
CITY filed a motion for judgment against surety on undertaking,
which motion was amended on June 10, 1986. Pursuant to said
amended motion, CITY sought to have the Judgment in Action No.
427262 entered against CARVERS, pursuant to the undertaking.
C. CARVERS are not presently able to pay the total amount
of the Judgment in Action No. 427262, and have represented to
CITY that they would be compelled to initiate bankruptcy proceed-
ings if CITY's motion were granted. In order to satisfy the
Judgment and reach a full and final settlement of all matters
pertaining to Action No. 427262, CITY and CARVERS have mutually
agreed that CARVERS shall pay the Judgment in installments as set
forth hereinbelow.
NOW, THEREFORE, in consideration of the mutual covenants set
forth herein, CITY and CARVERS agree as follows:
5/5/87
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1. On or before May 8, 1987, ARTHUR L. CARVER shallpay to
CITY the sum of $50,000.00 in full satisfaction of allclaims
which CITY may have against he and/or GERMAYNE CARVER, his
spouse, arising out of or related to the Judgment, the Litiga-
tion, or his undertaking filed as part of the Carver Corpora-
tion's appeal of the Judgment.
2. Beginning on May 1, 1987, BRUCE A. CARVER, SUSAN E.
CARVER and RANDALL B. CARVER (the "REMAINING CARVERS") shall pay
to CITY 103 equal payments of $1,000.36 on the first day of each
month, for a total of $103,038.88.
3. In consideration for said payments, CITY releases and
discharges CARVERS from all undertakings, claims, demands,
obligations or causes of action arising out of Action No. 427262.
This release applies only to CARVERS, and CITY expressly reserves
any and all causes of action that it has against any other party
to Action No. 427262. CARVERS shall be given credit against the
amount to be paid by them pursuant to this Agreement for any
amounts recovered by CITY from any other defendant in Action No.
427262 or Action No. 510842 which is also pending in the San
Diego Superior Court.
4. This Agreement shall become immediately null and void,
the obligations from which the REMAINING CARVERS are being
released shall become enforceable by CITY, and the REMAINING
CARVERS expressly waive any applicable statute of limitations
which may apply to enforcement of said obligations by CITY, upon
the occurrence of any of the following:
(a) Discovery that any misrepresentation was made
by any party in connection with the making of this
Agreement.
(b) Failure of the REMAINING CARVERS to make any
payment when due, if said failure is not remedied
within 15 days after CITY gives written notice of
default to the REMAINING CARVERS. Notice of default
will be deemed given two days after it is deposited in
the United States mail, first class postage prepaid,
addressed to:
Thomas C. Nelson, Esq.
McDonald, Hecht & Solberg
600 "B" Street, Suite 1100
San Diego, California 92101
In the event this Agreement is voided under this Section, the
REMAINING CARVERS shall be entitled to a credit against any
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amounts claimed by CITY for all payments made by CARVERS pursuant
to this Agreement.
5. This Agreement shall bind and inure to the benefit of
the parties and their heirs, legal representatives and assigns,
provided that this Agreement shall not be assigned by either
party without the mutual consent of the parties hereto.
6. This Agreement shall supersede the previous agreement
entered into by the parties in November 1986.
DATED: May 12, 1987
\PPROVED AS TO FO
George H. Eiser, III
.::ity Attorney
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CITY OF NATIONAL CITY
City Manager
BRUCE'A. CARVER
i XI / ? 7 /
%SUSAN E. CARVER
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RANDALL B. CARVER