HomeMy WebLinkAboutSettlement Agreement - CDC AARB, Beauchamp, Henschel, Bennett - 2007SETTLEMENT AGREEMENT AND MUTUAL RELEASE OF CLAIMS
THIS SETTLEMENT AGREEMENT AND MUTUAL RELEASE OF CLAIMS
("Agreement") is entered into by The Community Development Commission of the City of
National City (hereinafter referred to as the "CDC"), AARB, LLC, a California limited liability
company, Beauchamp Family Trust UDT 8/16/1982 as amended under Trust Amendment No.
One Dated 4/14/1986 ("Beauchamp Family Trust") (hereinafter AARB, LLC and Beauchamp
Family Trust are collectively referenced as "Developer"), the Henschel Trust, the Estate of
Arthur O. Henschel, Jr., San Diego Superior Court Case No. P189861 ("Henschel Estate"),
James L. Henschel, Arthur O. Henschel, III, and Charlene Bennett, all hereinafter sometimes
referred to collectively as the Parties.
I.
PURPOSE
This Agreement is made for the purpose of settling: (i) certain claims filed in the
Henschel Estate by Developer and CDC for Environmental Costs at the Properties; (ii) an
Eminent Domain Action filed by CDC to condemn the Property owned by the Henschel Trust;
(iii) claims made for Environmental Costs at the Property under the Polanco Redevelopment Act
by CDC naming the Henschel Trust and the Named Beneficiaries, which claims were joined in
the Eminent Domain Action. Undcr this Agreement the Property and other consideration is
transferred to the Developer in satisfaction of the environmental claims of CDC and
developer, the Named Beneficiaries disclaim any interest in the Property, and CDC and the
Developer release the Named Beneficiaries and the Henschel Trust and Henschel Estate from
claims and make certain payments.
II.
DEFINITIONS
1. "Agreement" means this Settlement Agreement and Mutual Release of Claims.
2. "Claims" means any and all claims that the CDC or Developer may have against
the Henschel Trust, .the Henschel Estate, or the Named Beneficiaries for the purpose of
recovering environmental investigation and remediation costs associated with the
Contamination (as defined below) at the Properties (as defined below).
3. "Contamination" means "hazardous substances" as that term is defined in the
Polanco Redevelopment Act (Health & Safety Code § 33459(c)) either in or on soil or
groundwater at or, if such "hazardous substances" arc found to be from the Properties, in the
vicinity of the Properties (as defined below).
4. "Environmental Costs" means investigation and remediation costs, including,
but not limited to, costs to investigate, remove or remediate hazardous substances in the soil and
groundwater at or from the Properties, analytical costs, reporting costs, and oversight costs from
the County of San Diego Department of Environmental Health ("DEH") or other appropriate
08-24-200? FINAL SAMRC
regulatory agency incurred by the CDC or Developer due to thc Contamination at the
Properties. Environmental Costs include, but is not limited to, all costs recoverable under the
Polanco Redevelopment Act.
5. "Past Environmental Costs" means Environmental Costs incurred by the CDC
or the Developer in the period ending on May 15, 2007, as a result of the Contamination.
6. "Future Environmental Costs" means Environmental Costs incurred by the
CDC or the Developer after May 15, 2007 due to the Contamination.
7. "Parties" means the CDC, the Henschel Trust, the Henschel Estate, the
Developer, and the Named Beneficiaries (as defined below).
8. "Named Beneficiaries" are the three named beneficiaries of the Henschel Trust,
to wit James Henschel, Arthur O. Henschel, III, and Charlene Bennett.
9. "Property" means 1031 Roosevelt Avenue, National City, California, Assessor
Parcel Number 555-113-04 which Property is the subject of the Eminent Domain Action by
CDC and which Property will be one parcel of the site of the Park Village Project to be built by
the Developer. The Property has historically been the site of a dry cleaning business.
10. "Former Drycleaners" means 901 Roosevelt Avenue (also referred to
historically as 32 W. 9th Street), National City, California, Assessor Parcel Number 555-084-01
which was the location of a dry cleaning business known as "The Barn" operated from
approximately 1966 to 1973 by Arthur O. Henschel, Jr. who did not own the real property.
After closure of "The Barn", Developer purchased the site and transformed it to automotive
uses. The Former Drycleaners is now the site of the Education Village project by CDC.
11. "Properties" refers collectively to the Property and the Former Drycleaners
III.
RECITALS
1. On December 1 , 2004 a Trust Transfer Deed was recorded as Doc. No. 2004-
1132902 by the County Recorder of San Diego County in which Arthur O. Henschel, Jr.
transferred the Property to his revocable trust known as the Henschel Trust. On December 12,
2004 Arthur O. Henschel, Jr. dicd and the Henschel Trust became irrevocable.
2. On May 31, 2005, CDC issued a notice to the Henschel Trust, as title holder to
the Property, pursuant to California Health & Safety Code section 33459, et seq. (the "Polanco
Redevelopment Act"), requesting that the Henschel Trust submit a remedial action plan for
hazardous substances released on, in or under the Property within sixty (60) days of receipt of
the notice. The Henschel Trust did not submit a proposed remedial action plan within the 60-day
notice period. On July 29, 2005, representatives of the Henschel Trust sent a letter expressing
an interest in cooperating with CDC to address the environmental concerns at the Property.
3. After motions by CDC, the Estate of Arthur O. Henschel, Jr. (aka Arthur Otto
Henschel, Jr.) Decedent, Case No. P 189861 in the Superior Court of San Diego County (herein
08-24-2007 FINAL SAMRC
n
"Henschel Estate") was opened and letters of administration issued December 5, 2005.
Developer and CDC each filed claims in the Henschel Estate for Past Environmental Costs and
Future Environmental Costs.
4. On February 3, 2006, CDC filed CDC of the City of National City v. Henschel
Trust, et. al, Case No. GIC 860857, in the Superior Court of San Diego County (the "Eminent
Domain Action") being an action in eminent domain to take the Property and making claims
under the Polanco Redevelopment Act for Environmental Costs at the Property. The
estimated amount for such Environmental Costs, according to the consultants for CDC, is in
excess of $2,000,000.
5. For the Purposes set forth above, the Parties desire to compromise and settle all
Claims relating to the matters addressed herein on the terms and conditions as set forth in this
Agreement.
IV.
TERMS OF SETTLEMENT AND RELEASE
IT IS HEREBY AGREED that:
1. CONSIDERATION
The Parties each agree to settle their claims of every kind between and among all
of them relating to the Past Environmental Costs, the Future Environmental Costs, the
Eminent Domain Action, the Polanco Redevelopment Act claims, the Properties, and all issues
arising therefrom, including all issues which were asserted or could have been asserted in the
Eminent Domain Action or the Henschel Estate, and all such claims are hereby expressly and
forever compromised, discharged, and terminated for all time, except any claims which may
arise from or pursuant to: (i) the obligations undertaken pursuant to this Agreement or the
Purchase Agreement provided for under this Agreement; or (ii) pursuant to paragraph 5(b)
hereof. In consideration of this settlement and mutual releases of the respective claims and the
mutual promises of the Parties herein set forth, the Parties agree to perform each of the terms
hereinafter set forth and abide by the terms of this Agreement.
2. PROPERTY TRANSFER AND LEDGER CLEANUP ACCOUNT
a. Transfer of Fcc Title to Real Property. In full and complete satisfaction of
any and all Claims that Developer or CDC may have against the Ienschel Trust, and in
settlement of the Eminent Domain Action, including the Polanco Redevelopment Act claims
asserted therein, and in consideration of the releases set forth herein, the Henschel Trust agrees
to transfer its interest in the Property to AARB, LLC pursuant to the terms and conditions of
the Purchase Agreement between the Henschel Trust and AARB, LLC, the form of which is
attached hereto as Exhibit "A". The signatories to Exhibit "A" agree to fully and faithfully
perform all the requirements of such Purchase Agreement. The Parties understand and agree
that if the Eminent Domain Action was fully litigated, the Henschel Trust would not likely
receive an award for the Property because the estimated Environmental Costs exceed the
appraised value of the Property in an uncontaminated condition, to wit $862,000 (the "Clean
06-24-2007 FINAL SAMRC
_3-
Value") and an offset would occur between the Clean Value and the estimated Environmental
Costs. Notwithstanding this fact, it is of value to CDC and Developer to enter into this
Agreement to conclude the litigation and limit the costs associated therewith. Upon execution
of this Agreement and the Purchase Agreement by the Henschel Trust and AARB, LLC, CDC
agrees to file a dismissal with prejudice of the Henschel Trust in the Eminent Domain Action .
b. Ledger Cleanup Account. The Clean Value will be the initial entry in a
Ledger Cleanup Account to be maintained by the Developer. The Developer of the project will
undertake any necessary investigation and remediation required by the oversight agency, and
will debit the 1,edgcr Cleanup Account for the following expenses as they are incurred: 1) a
$100,000 debit for the payment for Past Environmental Costs incurred by Developer as
detailed in section 2(c); 2) a $60,000 debit paid to the Named Beneficiaries and Trustee of the
Henschel Trust as detailed in section 3; 3) a debit for all delinquent taxes owing on the Property
paid by Developer through escrow; 4) debits for liens recorded against the Property by Union
Bank of California and by the State of California Department of Industrial Relations in the
amounts to be paid by the Developer to satisfy said liens at the time of payment of said amounts;
and 5) a debit for payment for Future Environmental Costs as detailed in section 2(d). The
CDC covenants that it will not approve any request of the Developer to assign, transfer or
alienate either the development rights or the property subject to this Agreement without
sufficient assurances that the Developer's obligations to the Henschel Trust, as stated in this
Agreement, are met.
c. Settlement for Past Environmental Costs . In return for the Release
specified herein, Henschel Trust agrees that Developer can debit the Ledger Cleanup Account for
payment of Past Environmental Costs incurred at the Properties by Developer in the amount
of $100,000. James Beauchamp, on behalf of Developer, represents and warrants that Developer
has incurred and made payment for Past Environmental Costs for the Properties in an amount
equal to or greater than $100,000.
d. Reimbursement for Future Environmental Costs. In return for the
Release specified herein, Ienschel Trust agrees to the dedication of the Ledger Cleanup Account
to reimburse Developer for all Future Environmental Costs incurred by Developer for the
activities required to investigate and remediate the Contamination at the Properties that the
lead or administering agency may approve. A summary of the expenditures made regarding these
activities and charged to the Ledger Cleanup Account, and the resulting balance, will be
provided to the I Ienschel Trust, or if no longer in existence its last Trustee, at least once per year.
The Parties agree that the decision of the regulatory oversight agency will be final with regard to
the scope of the work undertaken.
e. Remainder Shown on the Ledger Cleanup Account. Though it is likely
that the Environmental Costs will exceed the Ledger Cleanup Account, if any amount is shown
as remaining on the Ledger Cleanup Account at the earlier of: (i) seven years from the date
hereof; or (ii) the conclusion of all environmental work and payment of related Future
Environmental Costs as a result of the Contamination at the Properties, then such remainder
amount (including any accrued interest thereon) will be allocated and paid as follows: (i) the
first $200,000 thereof will be divided such that one half of such sum will be paid by the
Developer to the Henschel Trust and one half will be retained by the Developer; and (ii) any
OB-24-2007 FINAL SAMRC
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remainder amount in excess of $200,000 shall be paid to the Henschel Trust. If the Henschel
Trust is no longer in existence, any sums for the Henschel Trust shall be paid, in trust for the
Named Beneficiaries (or their designated heirs should a Named Beneficiary be then deceased),
to its last Trustee. The "conclusion of all environmental work" will occur upon receiving
satisfactory "closure" in the form of a "No Further Action" letter or other similar document from
the appropriate environmental oversight agency.
f. Interest on the Ledger Cleanup Account. The Ledger Cleanup Account
shall bear interest from May 15, 2007 at the rate of five percent (5%) per annum, compounded
monthly.
3. NAMED BENEFICIARIES DISCLAIMER
For and in settlement of any claims asserted against them in the Eminent Domain
Action, and in consideration of the releases set forth herein, the Named Beneficiaries agree to
execute a Disclaimer of Interest, in the form attached as Exhibit B hereto, disclaiming any
interest in the Property. Within fourteen (14) days after receipt of a fully executed copy of such
Disclaimer (s) from the Named Beneficiaries, CDC shall: (i) pay the sum of $10,000 directly to
each such Named Beneficiary; (ii) pay to the Trustee of the Henschel Trust the sum of
$30,000.00 as and for payment of the Trust's administrative expenses in conjunction with the
matters settled herein; and (iii) file a Request for Dismissal With Prejudice of each such Named
Beneficiary in the Eminent Domain Action.
4. CLAIMS IN HENSCHEL ESTATE
In as much as there are no assets in the Henschel Estate, the only claims filed
therein were and are those claims for Past Environmental Costs and Future Environmental Costs
by the Developer and CDC, and the Henschel Estate was only established to preserve such
claims for litigation purposes, within ten (10) days of their execution of this Agreement, CDC
and Developer agree to withdraw their respective claims in the Henschel Estate by filing a
"Withdrawal of Creditors Claim" therein. As soon as possible thereafter, the attorney for the
executor shall file a petition with the Court to terminate the Henschel Estate and discharge the
executor.
5. RELEASES OF PARTIES
a. Releases. Developer and CDC hereto, on behalf of themselves and, to the
maximum extent allowed by law, on behalf of their current and former agents, assigns,
successors, shareholders, partners, employees, officers, directors, predecessors, parent
companies, subsidiaries, affiliates, beneficiaries, affiliates, and attorneys, hereby fully release
and discharge the Henschel Trust, its current and former agents, trustees, assigns, successors,
shareholders, partners, employees, officers, directors, parent corporations, subsidiaries, affiliates,
predecessors, trusts, beneficiaries, including the Named Beneficiaries, and attorneys for any such
released parties, from any and all Claims for Environmental Costs (including both Past
Environmental Costs and Future Environmental Costs) or for other claims or costs related to
or arising from the Contamination at the Properties.
08-24-2007 FINAL SAMRC
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b. Limitations on Releases. The releases set forth in paragraph (a) above do
not include or apply to any rights of any of the Parties to enforce or interpret this Agreement or
an Exhibit hereto. In addition, nothing set forth in this Agreement shall in any way transfer,
assign, relinquish, exonerate, compromise, abrogate, waive or release any or all of the Claims
which any of the Parties may have against any person or entity not a party to this Agreement,
except to the extent such person or entity has been released in his, her or its capacity as a current
or former agent, trustee, assign, successor, partner, employee, subsidiary, affiliate, predecessor,
related entity or attorney for one of the Parties to this Agreement.
c. No Assignment. Each of the Parties represents and warrants to each other
that no portion of any Claim, demand, cause of action, or other matter released herein has been
or will be directly assigned or transferred to any other person or entity not a party to this
Agreement, other than sucu..ssors which agree to be bound to the terms of this Agreement.
Each of the Parties acknowledges that this representation is material to this Agreement, and that
each is relying upon said representation in entering into this Agreement.
6. GENERAL PROVISIONS
a. No Admissions. The Parties expressly acknowledge that execution of this
Agreement, consent to this settlement or the payment of any monies in accordance with this
Agreement shall not be deemed to be an admission of fault or liability on the part of any of the
Parties.
b. Successors and Assigns. All of the terms of this Agreement shall be
binding upon, inure to the benefit of, and be enforceable by the Parties hereto and their
respective legal representatives, successors, successors -in -title, executors and assigns.
c. Authorization to Enter Into Agreement. Each person executing this
Agreement represents and warrants that he or she has been duly authorized to execute this
Agreement on behalf of the Party and has full and complete authority to do so. Each of the
Parties expressly waives any defense to this Agreement based on any lack of authority to enter
into and be bound by the terms of this Agreement.
d. Agreement Not Admissible. This Agreement shall be deemed to fall
within the broadest protections afforded compromises and offers to compromise by California
Evidence Code section 1152, and any related provisions.
e. Governing Law. This Agreement shall be interpreted, construed,
governed and enforced under and pursuant to the laws of the State of California. Any action to
enforce or interpret this Agreement shall he filed and maintained within the County of San
Diego, State of California.
f. Advice of Counsel. Each of the Parties has been or has had the
opportunity to be represented in the negotiation and preparation of this Agreement by
independent legal counsel of its own choosing. Each of the Parties further represents that he or
she has read this Agreement and that he or she is fully aware of its content and legal effect and
enters into the Agreement voluntarily, freely and without coercion. Each of the Parties agrees
08-24-2(107 PTNA1. SAMRC
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and represents that, except as set forth in this Agreement, no promise, inducement,
understanding, representation, warranty or agreement has been made or relied upon in
connection with the execution of this Agreement. Each of the Parties assumes the risk of any
purported mistake, misunderstanding, misrepresentation or nondisclosure and shall have no
alleged right or claim to set aside or rescind this Agreement based thereon.
g. Entire Agreement. This Agreement constitutes the entire agreement
between the Parties pertaining to resolution of the Claims covered herein.
h. Waiver and Amendment. No breach of any provision hereof can be
waived unless in writing. Waiver of any one breach shall not be deemed to be a waiver of any
other breach of the same or any other provision hereof. This Agreement may be amended only
in a writing executed by all of the affected Parties.
i. No Presumption Regarding Construction. The Parties and their attorneys
have cooperated in drafting and preparing this Agreement. Consequently, the presumption that
ambiguities are resolved against the drafting Party shall be inapplicable, and any such
ambiguities shall not be construed against such drafting Party.
j. Severability. If any term or provision of this Agreement is found by a
court to be void and unenforceable, that finding shall in no way affect any other provision of this
Agreement or any document to be executed concurrently herewith or the validity or
enforceability of the Agreement as a whole,
k. Attorneys' Fees and Costs. The Parties shall bear their own attorneys'
fees, costs and all other expenses (with the exception of Environmental Costs) incurred to date
except as set forth in Exhibit A hereto. In the event it becomes necessary for any Party to
obtain the services of an attorney to bring a suit, claim, action or proceeding to enforce or
interpret the provisions of this Agreement against any Party who has breached any obligation
set forth herein, the prevailing Party shall be entitled to recover its reasonable attorneys fees,
costs of suit and related legal expenses.
1. Parties in Interest/No Third Party Beneficiaries. This Agreement has
been made and is made solely for the benefit of the Parties to this Agreement, and their
respective successors and assigns, and no other person or entity shall acquire or have any rights
under or by virtue of this Agreement. In addition, nothing in this Agreement is intended to
release or discharge the obligation or liability of any third persons to any of the Parties to this
Agreement.
m. Notices. All notices required or permitted under this Agreement shall be
in writing (either by mail or facsimile), and addressed to the Parties for whom it is intended at
the address set forth herein or such other address designated from time to time in writing to all
other Parties:
O8-24-2007 FINAL SAMkC
-7-
To the Agency:
The Community Development Commission of the City of National City
Attn: Ms. Patricia Beard
Redevelopment Manager
1243 National City Blvd.
National City, CA 91950
With a copy to:
Opper & Varco LLP
Richard Opper, Esq.
225 Broadway, 191h Floor
San Diego, CA 92101
Telephone: (619) 231-5858
Facsimile: (619) 231-5853
To the Developer:
AARB,LLC
James Beauchamp, Manager
Alton B. Beauchamp, Trustee
Beauchamp Family Trust
327 West 1 lth Street
National City, CA 91950
To Henschel Trust:
The Henschel Trust
c/o Antonia E. Martin, Esq., Trustee
Law Offices of Antonia E. Martin
401 West "A" Street, Suite 1775
San Diego, CA 92101-7901
Telephone: (619) 231-7575
Facsimile: (619) 231-7593
To Henschel Estate:
Estate of Arthur O. Henschel
c/o Antonia E. Martin, Esq., Executor
Law Offices of Antonia E. Martin
401 West "A" Street, Suite 1775
San Diego, CA 92101-7901
Telephone: (619) 231-7575
Facsimile: (619) 231-7593
08-24-2007 RNA!. SAMRC
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To Named Beneficiaries:
James I,. Henschel
432 Madison Avenue
Boonton, NJ 07005
Arthur 0, Henschel, III
9100 Single Oak Dr., Space 30
Lakeside, CA
Charlene Bennett
1802 Plaza Drive, Apt 15
Elwood, IN 46036
Any notice so delivered or served shall be deemed made upon receipt by the Parties served or to
whom notice is so given. Notice may also be made by electronic mail transmission or by
facsimile transmission and deemed made as of the date and time of that transmission, if said
notice is followed up by duplicate written notice sent by certified United States mail, retum
receipt requested, postage prepaid, prior to the close of the next business day.
n. Counterparts. This Agreement may be executed in any number of
separate counterparts, each of which shall be deemed an original but all of which when taken
together shall constitute one and the same instrument.
o. Further Documents. The Parties hereto shall execute and deliver all
documents and perform all further acts that may be reasonably necessary to effectuate the
provisions of this Agreement.
OS-24-2007 FINAL SAMRC
(Remainder of page left intentionally blank]
-9-
IN WITNESS WHEREOF, the Parties enter into this Agreement which shall become
effective and fully enforceable in all respects as of the latest date that this Agreement is fully
executed by the Parties.
Dated: C! /fiJV7
Dated:
THE COMMUNITY DEVELOPMENT COMMISSION
OF THE CITY OF..NATIONAL CITY
By:
Name: pher Zapata
Title: Exc ive Director
THE HENSCHEL TRUST
By:
Name: Antonia E. Martin, Trustee
The Estate of Arthur O. Henschel, Jr. Deceased
Dated: By:
Dated:
Dated:
Dated:
Dated:
08-24-2007 FINAL SAMRC
Antonia E. Martin, Esq. Executor
James L. Henschel
Arthur O. Hesnchel, III
Charlene Bennett
AARB, LLC
-10-
1
ames Beauchamp, Manager
IN WITNESS WHEREOF', the Parties enter into this Agreement which shall become
effective and fully entbrceable in all respects as of the latest date that this Agreement is fully
executed by the Parties.
Dated:
THE COMMUNITY DEVELOPMENT COMMISSION
OF'1'HE CITY OF NATIONAI, CITY
By:
Name: Christopher Zapata
Title: Executive Director
TIIE HENSCHEI., .I'RUST
Dated: of 0 / By: _
Name:
Dated:
I )ated:
Dated:
Dated:
l'4/.2,067
Antonia E. Martin, Trustee
The Estate of Arthur O. Henschel, Jr. Deceased
By:
Antonia E. Martin, Esq. Executor
James I,. Henschel
Arthur O. IIesnchel, Iil
Charlene Bennett
AARB, LLC
Dated: By:
08-24-2007 FINAL SAMRC
James Beauchamp, Manager
- 10-
IN WITNESS WHEREOF, the Parties enter into this Agreement which shall become
effective and fully cnlorceablc in all respects as of the latest date that this Agreement is fully
executed by the Parties.
Dated:
Dated:
Dated:
Dated: 9 '9 • o'�
Dated:
Dated:
TIIE COMMUNITY DEVELOPMENT COMMISSION
OF THE CITY OF NATIONAL CITY
By:
Name:
Title:
Christopher Zapata
Executive Director
THE HENSCIIEL TRUST
By:
Name: Antonia E. Martin, Trustee
The Estate of Arthur O. IIenschel, Jr. Deceased
By:
Antonia E. Martin, Esq. Executor
hel
Arthur O. Hesnchel, III
Charlene Bennett
AARB, LLC
Dated: Bv:
OR-24-2007 FINAL SAMRC
James Beauchamp, Manager
- 10-
IN WITNESS WHEREOF, the Parties enter into this Agreement which shall become
effective and fully enforceable in all respects as of the latest date that this Agreement is fully
executed by the Parties.
Dated:
1)ated:
THE COMMUNITY DEVELOPMENT COMMISSION
OF TIHE CITY OF NATIONAL CITY
By:
Name: Christopher Zapata
Title: Executive Director
TIIE IIENSCIIEL TRUST
By:
Name: Antonia E. Martin, Trustee
The Estate of Arthur O. I Ienschel, Jr. I )eccased
Dated: By:
Dated:
Dated: 49-0 7-0 7
1)atcd:
Antonia E. Martin, Esq. Executor
James L. IIenschel
Arthur 0. Hesnchel, III
Charlene Bennett
AARB, LLC
Dated: I3y:
08-24-2007 FINAI. SAMRC
James Beauchamp, Manager
- 10 -
09/07/07 FRI 11:35 FAX 619 238 1981 MULVANEY.KAHAN.& BARRY
Ij 003
IN WITNESS WHEREOF, the Parties enter into this Agreement which shall become
effective and fully enforceable in all respects as of the latest date that this Agreementfully
executed by the Parties.
THE COMMUNITY DEVELOPMENT COMMISSION
OF THE CITY OF NATIONAL CITY
Dated: _ By:
Name: Christopher Zapata
'Title: Executive Director
Dated:
Dated:
Dated:
Dated:
q
Dated:
Dated:
O8-24.2007 FINAL SAMRC
THE HENSCHEL TRUST
By:
Name: Antonia E. Martin, Trustee
The Estate of Arthur O. Henschel, Jr. Deceased
By:
Antonia E. Martin, Esq. Executor
James L. Henschel
Arthur O. Hennchel, llI
Charlene Bennett
AARB, LLC
By:
James Beauchamp, Manager
Dated:
Richard G. Opper
Opper & Varco LLP
Special Environmental Counsel to the
Community Development Commission
of the City of National City
George Eiser
City Attorney
City of National City
BEAUCHAMP FAMILY TRUST
By:
Alton B. Beauchamp, Trustee
Robert G. Russell, Jr.
Procopio, Cory, Hargreaves & Savitch LLP
Environmental Counsel to the Henschel Trust
Sandra Brower, Esq.
Wertz McDade Wallace Moot & Brower
Attorney for AARB, LLC, and
Alton B. Beauchamp as Trustee
of the Beauchamp Family Trust
08-24-2007 FINAL SAMRC
- 11 -
BEAUCIIAMP FAMILY TRUST
Dated: By:
Alton B. Beauchamp, Trustee
APPROVED AS TO FORM:
Richard G. Opper
Opper & Varco LLP
Special Environmental Counsel to the
Community Development Commission
of the City of National City
George Eiscr
City Attg4ney
City of
Robert G. Russell, Jr.
Procopio, Cory, Hargreavesf& Savitch LLP
Environmental Counsel to the Henschel Trust
Sandra Brower, Esq.
Wertz McDade Wallace Moot & Brower
Attorney for AARB, LLC, and
Alton B. Beauchamp as Trustee
of the Beauchamp Family Trust
08-24-2007 FINAL SAMRC
- 11 -
BEAUCHAMP FAMILY TRUST
Dated: By:
APPROVED AS TO FORM:
Richard G. Opper
Opper & Varco LLP
Special Environmental Counsel to the
Community Development Commission
of the City of National City
George Eiser
City Attorney
City of National City
Robert G. Russell, Jr.
Procopio. Cory, Hargreaves & Savitch LLP
Environmental Counsel to the I-Ienschel Trust
i ra Brower, E
Wertz McDac 'allace Moot & Brower
Attorney AARB, LLC, and
Alton . Beauchamp as Trustee
of the Beauchamp Family Trust
a8.24-2U07 FINAL SAMRC
-11-
Alton B. Beauchamp, Trustee
Dated:
APPROVED AS TO FORM:
Richard G. Opper
Opper & Varco LLP
Special Environmental Counsel to the
Community Development Commission
of the City of National City
George Eiser
City Attorney
City of National City
BEAUCHAMP FAMILY TRUST
By:
Alton B. Beauchamp, Trustee
Robert G. Russell, Jr.
Procopio, Cory, Hargreaves & Savitch LLP
Environmental Counsel to the Henschel Trust
Sandra Brower, Esq.
Wertz McDade Wallace Moot & Brower
Attorney for AARB, LLC, and
Alton B. Beauchamp as Trustee
of the Beauchamp Family Trust
OR-24-2007 FINAL SAMRC
- 1 I -
RESOLUTION NO. 2007 — 224
RESOLUTION OF THE COMMUNITY DEVELOPMENT
COMMISSION OF THE CITY OF NATIONAL CITY ("CDC")
AUTHORIZING THE EXECUTIVE DIRECTOR TO EXECUTE
A SETTLEMENT AND RELEASE OF CLAIMS AGREEMENT
WITH AARB LLC, BEAUCHAMP FAMILY TRUST, THE HENSCHEL TRUST,
THE ESTATE OF ARTHUR 0 HENSCHEL JR., JAMES L HENSCHEL,
ARTHUR 0 HENSCHEL III, AND CHARLENE BENNETT RELATED
TO ENVIRONMENTAL COSTS, EMINENT DOMAIN ACTION
BY THE CDC, AND CLAIMS FOR ENVIRONMENTAL COSTS
UNDER THE POLANCO REDEVELOPMENT ACT
FOR THE PARK VILLAGE PROJECT
WHEREAS, on February 22, 2005, the Community Development Commission of
the City of National City ("CDC") entered into an Owner Participation Agreement ("OPA") with
the Beauchamp Family Trust for a project called Park Village ("Project"), located within the block
bounded by National City Boulevard, Plaza Boulevard, Roosevelt Avenue, and 11 u, Street; and
WHEREAS, the Henschel Trust owns property within the Project which has been
impacted by hazardous substances from historical land uses including a dry cleaning plant; and
WHEREAS, on December 13, 2005, the CDC adopted Resolution No. 2005-113
authorizing the transfer of the OPA to AARB, LLC; and
WHEREAS, on February 3, 2006, the CDC filed Case No. GIC 860857 in the
Superior Court of San Diego County being an action in eminent domain to take the Property and
making claims under the Polanco Redevelopment Act for Environmental Costs at the Property;
and
WHEREAS, CDC consultants estimated the value of the Environmental Costs at
more than $2 million; and
WHEREAS, the Parties now desire to settle all claims and matters between them
including Past Environmental Costs, Future Environmental Costs, the Eminent Domain Action,
and the Polanco Act Redevelopment Claims.
NOW, THEREFORE, BE IT RESOLVED that the Community Development
Commission of the City of National City authorizes the Executive Director to execute a
Settlement Agreement and Mutual Release of Claims with AARB, LLC., the Beauchamp Family
Trust; the Henschel Trust; the estate of Arthur O. Henschel, Jr., James L. Henschel, Arthur O.
Henschel HI, and Charlene Bennett. Said Agreement is on file in the office of the City Clerk.
PASSED and ADOPTED this 18th day of
ATTES
-suOIMP
Ron Morrison, Chairman
APPROVED AS TO FORM:
Brad Raulstonetary George H. Liser, III
Legal Counsel
Passed and adopted by the Community Development Commission of the City of National
City, Califomia, on September 18, 2007, by the following vote, to -wit:
Ayes: Commissioners Morrison, Natividad, Parra, Ungab.
Nays: None.
Absent: Commissioner Zarate.
Abstain: None.
AUTHENTICATED BY: RON MORRISON
Chairman, Community Development Commission
Secretary, ommunity Development Commission
By:
Deputy
I HEREBY CERTIFY that the above and foregoing is a full, true and correct copy of
RESOLUTION NO. 2007-224 of the Community Development Commission of the City of
National City, Califomia, passed and adopted on September 18, 2007.
Secretary, Community Development Commission
By:
Deputy
City of National City, California
COMMUNITY DEVELOPMENT COMMISSION AGENDA STATEMENT
MEETING DATE September 18, 2007 AGENDA ITEM NO. 12
(-ITEM TITLE A RESOLUTION AUTHORIZING THE EXECUTIVE DIRECTOR TO\
EXECUTE A SETTLEMENT AND RELEASE OF CLAIMS AGREEMENT WITH
AARB LLC, BEAUCHAMP FAMILY TRUST, THE HENSCHEL TRUST, THE
ESTATE OF ARTHUR 0 HENSCHEL JR., JAMES L HENSCHEL, ARTHUR 0
HENSCHEL 111, AND CHARLENE BENNETT RELATED TO ENVIRONMENTAL
COSTS, EMINENT DOMAIN ACTION BY THE CDC AND CLAIMS FOR
ENVIRONMENTAL COSTS UNDER THE POLANCO REDEVELOPMENT ACT
FOR THE PARK VILLAGE PROJECT.
PREPARED BY DEPARTMENT
Patricia Beard Redevelopment Division
Redevelopment Manager, 4255
EXPLANATION The Henschel property is located at 1031 Roosevelt Avenue within the
footprint of the Park Village project. This Agreement settles acquisition of the Henschel
property for the project as well as environmental claims and costs against the Henschel
Trust. The Agreement allows transfer of title and environmental responsibility for the property
to AARB, LLC, developers of Park Village.
Environmental Review Not applicable.
Strategic Plan Goals 5A: Implement Downtown Specific Plan through establishing Market
Supported Values.
Financial Statement There is no cost to the CDC for this Agreement. AARB is required to
reimburse all legal and environmental costs per terms of its Owner Participation Agreement,
Account No 900912
STAFF RECOMMENDATION Adopt the resolution.
BOARD / COMMISSION RECOMMENDATION Not applicable.
ATTACHMENTS
1. Proposed Settlement Agreement and Mutual Release of
Claims
Resolution No. a o 0I- a a y
City of National City
Office of the City Clerk
1243 National City Boulevard, National City, CA 91950-4397
Michael R. Dalla, CMC - City Clerk
(619) 336-4228 Fax: (619) 336-4229
September 24, 2007
Mr. Arthur O. Henschel, III
9100 Single Oak Drive, Space 30
Lakeside, CA 92040
Dear Mr. Henschel,
On September 18, 2007, Resolution No. 2007-224 was passed and adopted by
the Community Development Commission of National City, authorizing execution
of a settlement and release of claims agreement with AARB LLC, Beauchamp
Family Trust, The Henschel Trust, The Estate of Arthur O. Henschel Jr., James
L. Henschel, Arthur O. Henschel III, and Charlene Bennett.
We are enclosing for your records a certified copy of the above Resolution and a
fully executed copy of the agreement.
Michael R. Dalla, CMC
City Clerk
Enclosure
cc: Community Development Commission
® Recycled Paper
City of National City
Office of the City Clerk
1243 National City Boulevard, National City, CA 91950-4397
Michael R. Della, CMC - City Clerk
(619) 336-4228 Fax: (619) 336-4229
September 24, 2007
Mr. Richard Opper, Esq.
Opper & Varco LLP
225 Broadway, 19th Floor
San Diego, CA 92101
Dear Mr. Opper,
On September 18, 2007, Resolution No. 2007-224 was passed and adopted by
the Community Development Commission of National City, authorizing execution
of a settlement and release of claims agreement with AARB LLC, Beauchamp
Family Trust, The Henschel Trust, The Estate of Arthur O. Henschel Jr., James
L. Henschel, Arthur O. Henschel III, and Charlene Bennett.
We are enclosing for your records a certified copy of the above Resolution and a
fully executed copy of the agreement.
Sincerely,
Michael R. Dalla, CMC
City Clerk
Enclosure
cc: Community Development Commission
® Recycled Paper
City of National City
Office of the City Clerk
1243 National City Boulevard, National City, CA 91950-4397
Michael R. Dalla, CMC - City Clerk
(619) 336-4228 Fax: (619) 336-4229
September 24, 2007
Mr. James Beauchamp
Manager
AARB, LLC
Beauchamp Family Trust
327 West 11th Street
National City, CA 91950
Dear Mr. Beauchamp,
On September 18, 2007, Resolution No. 2007-224 was passed and adopted by
the Community Development Commission of National City, authorizing execution
of a settlement and release of claims agreement with AARB LLC, Beauchamp
Family Trust, The Henschel Trust, The Estate of Arthur O. Henschel Jr., James
L. Henschel, Arthur O. Henschel III, and Charlene Bennett.
We are enclosing for your records a certified copy of the above Resolution and a
fully executed copy of the agreement.
Michael R. Dalla, CMC
City Clerk
Enclosure
cc: Community Development Commission
® Recycled Paper
City of National City
Office of the City Clerk
1243 National City Boulevard, National City, CA 91950-4397
Michael R. Della, CMC - City Clerk
(619) 336-4228 Fax: (619) 336-4229
September 24, 2007
The Henschel Trust
c/o Antonia E. Martin, Esq., Trustee
Law Offices of Antonia E. Martin
401 West A Street, Suite 1775
San Diego, CA 92101-7901
Dear Ms. Martin,
On September 18, 2007, Resolution No. 2007-224 was passed and adopted by
the Community Development Commission of National City, authorizing execution
of a settlement and release of claims agreement with AARB LLC, Beauchamp
Family Trust, The Henschel Trust, The Estate of Arthur O. Henschel Jr., James
L. Henschel, Arthur O. Henschel III, and Charlene Bennett.
We are enclosing for your records a certified copy of the above Resolution and a
fully executed copy of the agreement.
Michael R. Dalla, CMC
City Clerk
Enclosure
cc: Community Development Commission
® Recycled Paper
City of National City
Office of the City Clerk
1243 National City Boulevard, National City, CA 91950-4397
Michael R. Della, CMC - City Clerk
(619) 336-4228 Fax: (619) 336-4229
September 24, 2007
Estate of Arthur O. Henschel
c/o Antonia E. Martin, Esq., Executor
Law Offices of Antonia E. Martin
401 West A Street, Suite 1775
San Diego, CA 92101-7901
Dear Ms. Martin,
On September 18, 2007, Resolution No. 2007-224 was passed and adopted by
the Community Development Commission of National City, authorizing execution
of a settlement and release of claims agreement with AARB LLC, Beauchamp
Family Trust, The Henschel Trust, The Estate of Arthur O. Henschel Jr., James
L. Henschel, Arthur O. Henschel III, and Charlene Bennett.
We are enclosing for your records a certified copy of the above Resolution and a
fully executed copy of the agreement.
Sincerely,
Michael R. Della, CMC
City Clerk
Enclosure
cc: Community Development Commission
® Recycled Paper
City of National City
Office of the City Clerk
1243 National City Boulevard, National City, CA 91950-4397
Michael R. Della, CMC - City Clerk
(619) 336-4228 Fax: (619) 336-4229
September 24, 2007
Mr. James L. Henschel
432 Madison Avenue
Boonton, NJ 07005
Dear Mr. Henschel,
On September 18, 2007, Resolution No. 2007-224 was passed and adopted by
the Community Development Commission of National City, authorizing execution
of a settlement and release of claims agreement with AARB LLC, Beauchamp
Family Trust, The Henschel Trust, The Estate of Arthur O. Henschel Jr., James
L. Henschel, Arthur O. Henschel III, and Charlene Bennett.
We are enclosing for your records a certified copy of the above Resclution and a
fully executed copy of the agreement.
Michael R. Dalla, CMC
City Clerk
Enclosure
cc: Community Development Commission
® Recycled Paper
City of National City
Office of the City Clerk
1243 National City Boulevard, National City, CA 91950-4397
Michael R. Della, CMC - City Clerk
(619) 336-4228 Fax: (619) 336-4229
September 24, 2007
Ms. Charlene Bennett
1802 Plaza Drive, Apt. 15
Elwood, IN 46036
Dear Ms. Bennett,
On September 18, 2007, Resolution No. 2007-224 was passed and adopted by
the Community Development Commission of National City, authorizing execution
of a settlement and release of claims agreement with AARB LLC, Beauchamp
Family Trust, The Henschel Trust, The Estate of Arthur O. Henschel Jr., James
L. Henschel, Arthur O. Henschel III, and Charlene Bennett.
We are enclosing for your records a certified copy of the above Resolution and a
fully executed copy of the agreement.
Michael R. Dalla, CMC
City Clerk
Enclosure
cc: Community Development Commission
® Recycled Paper