HomeMy WebLinkAboutRES.983.09-19-1994 BILL NO. 94-249 RESOLUTION NO. �%�_,�
A RESOLUTION AUTHORIZING THE CITY MANAGER TO
ENTER INTO A SETTLEMENT AGREEMENT WITH CAPE
CENTRAL AIRWAYS, INC.
BE IT RESOLVED BY THE COUNCIL OF THE CITY OF CAPE GIRARDEAU,
MISSOURI, AS FOLLOWS:
ARTICLE 1. The City Manager, for and on behalf of the City of
Cape Girardeau, Missouri, is hereby authorized to enter into a
Settlement Agreement with Cape Central Airways, Inc. A copy of
said Agreement is attached to this Resolution and made a part
hereof.
The City Manager's authorization to enter into this Settlement
Agreement with Cape Central Airways, Inc. is contingent on the
City's reaching agreement with Air Evac EMS, Inc. and the execution
of a Lease and Operations Agreement with Air Evac EMS, Inc. for the
premises now occupied by Cape Central Airways, Inc.
PASSED AND ADOPTED THIS 1 �,�. i DAY OF � , 19 `�.
A. M. radling, Mayor
ATTEST:
�, /
Gayle . Conrad
Deputy City Clerk
r
[CONFIDENTIAL COMMUNICATION
SUBJECT TO ATTORNEY-CLIENT PRIVILEGE INTENDED TO APPLYI
[NOT INTENDED FOR PUBLIC VIEWING]
SETTLEMENT AGREEMENT
THIS AGREEMENT, made and entered into this day of
, 1994 , by and between the City of Cape
Girardeau, Missouri, a Municipal Corporation of the State of
Missouri, hereinafter called "City" , and Cape Central Airways,
Inc. , a Missouri Corporation, Box 99, Cape Girardeau, Missouri, by
and through its President, Mark Spatz, hereinafter called "Cape
Central" ;
WITNESSETH:
WHEREAS, the parties to this Agreement have previously entered
into a "Lease and Operations Agreement" dated April 7, 1992 ,
wherein the City leased to Cape Central certain land and
improvements located at the Cape Girardeau Municipal Airport in
Scott County, Missouri; and
WHEREAS, disputes have arisen between the City and Cape
Central regarding interpretation of the Lease and Operations
Agreement and with respect to the rights and obligations of the
parties to the Lease and Operations Agreement; and
WHEREAS, the result of the dispute between the parties is that
there is now litigation pending between the parties in the
Associate Circuit Court of Scott County, Missouri, in a case known
as City of Cape Girardeau Missouri v Cape Central Airwavs, Inc. ,
Case No. CV594-370AC and an additional suit pending in the Circuit
Court of Scott County, Missouri, known as City of Cape Girardeau,
Missouri v Cape Central Airwavs, Inc. , Case No. CV394-386CC; and
[CONFIDENTIAL COMMUNICATION
SUBJECT TO ATTORNEY-CLIENT PRIVILEGE INTENDED TO APPLY]
[NOT INTENDED FOR PUBLIC VIEWING]
WHEREAS, Cape Central is contemplating bringing counterclaims
in those suits and both parties anticipate long and costly
litigation to resolve their disputes; and
WHEREAS, both parties desire to settle their differences
amicably and completely and without resort to further litigation.
NOW, THEREFORE, in consideration of the mutual promises,
agreements and releases made herein, the parties agree to bind
themselves as follows:
1. The parties agree that contemporaneously with the
execution of this document, that the Lease and Operations Agreement
between the parties previously entered into April 7, 1992 , is
hereby terminated by mutual agreement of the parties and that
possession of the premises is hereby returned to the City effective
immediately.
2 . That effective immediately upon the execution of this
Settlement Agreement, the parties are released of all obligations
to one another contained in the Lease and Operations Agreement and
that Cape Central has no further right to possession or use of the
premises. Cape Central will remove all its property from the
premises immediately and any property left on the premises after
the execution of this Agreement is deemed abandoned to the City.
3 . The City agrees to dismiss both suits hereinabove
referred to and both parties agree to pay their own costs of such
2 .
[CONFIDENTIAL COMMUNICATION
SUBJECT TO ATTORNEY-CLIENT PRIVILEGE INTENDED TO APPLY]
[NOT INTENDED FOR PUBLIC VIEWING]
litigation, including filing fees, attorney fees or any other costs
associated with the litigation.
4 . Cape Central Airways, Inc. hereby releases and forever
discharges the City of Cape Girardeau, Missouri, its agents,
servants, employees and assigns and all other persons, firms or
corporations liable or who might be claimed to be liable, all of
whom deny any liability, of and from any and all claims, suits,
demands, and causes of action of every kind and character, whether
legal or equitable in nature, which have accrued or may hereafter
accrue, for or on account of damages of every character and
description in any way arising out of or resulting from the
contractual relationship of the City of Cape Girardeau and Cape
Central Airways by virtue of the Lease and Operations Agreement
dated April 7, 1992 ; by reason of any disagreements between the
parties with respect to interpretation or termination of the Lease
and Operations Agreement or with respect to any action taken or
statements made relative to the disagreement of the parties or the
termination of the Lease and Operations Agreement.
5. The City of Cape Girardeau, Missouri, hereby releases and
forever discharges Cape Central Airways, Inc. , its agents,
servants, employees and assigns and all other persons, firms or
corporations liable or who might be claimed to be liable, all of
whom deny any liability, of and from any and all claims, suits,
demands, and causes of action of every kind and character, whether
3 .
[CONFIDENTIAL COMMUNICATION
SUBJECT TO ATTORNEY-CLIENT PRIVILEGE INTENDED TO APPLY]
[NOT INTENDED FOR PUBLIC VIEWING]
legal or equitable in nature, which have accrued or may hereafter
accrue, for or on account of damages of every character and
description in any way arising out of or resulting from the
contractual relationship of the City of Cape Girardeau and Cape
Central Airways by virtue of the Lease and Operations Agreement
dated April 7, 1992 ; by reason of any disagreements between the
parties with respect to interpretation or termination of the Lease
and Operations Agreement or with respect to any action taken or
statements made relative to the disagreement of the parties or the
termination of the Lease and Operations Agreement.
6. The promises and agreements made herein are contingent on
the sale of Cape Central's assets by the terms of an agreement
reached separately with Air Evac EMS, Inc. and are further
contingent on the execution of a Lease Agreement between the City
and Air Evac EMS, Inc. for the premises now occupied by Cape
Central Airways, Inc.
4 .
Y
[CONFIDENTIAL COMMUNICATION
SUBJECT TO ATTORNEY-CLIENT PRIVILEGE INTENDED TO APPLY]
[NOT INTENDED FOR PUBLIC VIEWING]
7 . This Agreement is binding on the successors and assigns
of the parties hereto.
CITY OF CAPE GIRARDEAU, MISSOURI
J. Ronald Fischer, City Manager
ATTEST:
Gayle L. Conrad, Deputy City Clerk
CAPE CENTRAL AIRWAYS, INC.
Mark Spatz, President
ATTEST:
Secretary
5.