HomeMy WebLinkAboutGolden Bay Construction - Settlement Agreement
SETTLEMENT AGREEMENT
This Settlement Agreement dated May\!L, 2010 ("Agreement") is entered into by and
between GOLDEN BAY CONSTRUCTION, INC., a California corporation ("Golden Bay") and
the CITY OF GILROY, a California municipal corporation ("Gilroy").
RECITALS
This Agreement is made with reference to the following facts:
A. On or about February 21, 2006, Gilroy and Golden Bay entered into a written
contract entitled "Monterey Streetscape Improvement Project, Phase III, Project No. 06-CDD-
119, Federal Project No. CML-5034 (012) as modified by Addenda Nos. 1,2 and 3 ("Contract")
pursuant which Golden Bay agreed to complete the work shown on the plans dated November 8,
2005 and as described in the specifications entitled City of Gilroy Specifications for Monterey
Streetscape Improvement Project, Phase III, Federal Project No. CML-5034 (012) City Project
No. 06-CDD-119 ("Project").
B. During the course of the Project, certain disputes arose between Gilroy and
Golden Bay regarding various delays and disruptions. Golden Bay alleges that its work had been
subject to delay, disruption and interference from circumstances beyond its control and for which
Gilroy is responsible. Golden Bay further alleges that it has incurred additional costs, expenses,
losses and various inefficiencies as a result of this delay, disruption and interference in an
amount exceeding $240,000.00. Gilroy disputes that it is responsible for delays, disruption or
interference.
C. Gilroy contends that Golden Bay has not diligently prosecuted the work and is
responsible for various delays on the Project. Accordingly, Gilroy has informed Golden Bay that
it may be assessed liquidated damages for 75 calendar days at the rate of $3,500.00 per day for
each calendar day the Project is delayed, and possibly more. Gilroy also contends that the
concrete work performed by Golden Bay does not meet Project requirements in that (a) Gilroy
contends the curing compound applied to the concrete sidewalks allegedly gives the concrete an
uneven, mottled appearance when viewed under certain conditions, (b) the color of adjacent
concrete panels allegedly does not match as closely as the City desires, and ( c) there allegedly
are minor cracks in the concrete at certain locations. Golden Bay disputes that it is responsible
for delays to the Project and that its work materially deviates from the requirements for the
Project.
D.
follows:
Gilroy and Golden Bay wish to avoid potential litigation and therefore agree as
AGREEMENT
1. Incorporation of Recitals. Paragraphs A through C of the Recitals are
incorporated as though fully set forth herein.
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2. Terms of Settlement.
(a) Power Washing of Monterey Street. Every six months, beginning in
December, 2010, and continuing for a period of 10 years (for a total of 20 times) Golden Bay
will pressure wash/steam clean the concrete, brick, aggregate surfaces, benches, trash cans and
lamps on both sides of Monterey Street beginning from the South side of the Fourth Street
intersection to the North side of the Eighth Street intersection, in Gilroy, California. Golden Bay
will use a minimum of 3,000 PSI water, heated to 180 degrees Fahrenheit to clean the surfaces of
dirt, grime, oils, grease, organic growth and other surface debris. Golden Bay shall use a metal
scraper to assist in the removal of gum. Golden Bay shall clean as aggressively as possible
without damaging the surface of the concrete, brick, aggregate, benches, trash cans or lamps, and
the quality of its work shall equal or exceed the quality of a professional power washing
company. Golden Bay shall not use cold water machines or "turbo nozzles". Gilroy shall have
the right to direct Golden Bay to power wash/steam clean more frequently than every six months,
but Golden Bay shall not be obligated to power wash/steam clean more than a total of 20 times.
Golden Bay will give Gilroy seventy-two hours advance notice of the completion of the power
washing so a Gilroy representative can be onsite to review the power washing upon completion.
Golden Bay Construction will perform additional power washing at any areas that are not done
to the City of Gilroy's satisfaction during the same visit.
(b) Payment of Contract Balance by Gilroy. Within ten (10) business days of
this Agreement being approved by the City Council, Gilroy will pay Golden Bay the sum of
$21,408.00.
(c) Replacement of Grout/Caulking Along Monterev Street. Golden Bay,
either directly or through a subcontractor, will remove and replace the existing concrete grout
and caulk between the bricks and between the bricks and the concrete flatwork along Monterey
Street with Gray Sonneborn SL2, from the north side of the Fourth Street intersection to the
north side of the Sixth Street intersection. The work will be limited to the joint that runs parallel
to Monterey Street at the back of the brick park strip between the concrete sidewalk and the
bricks on both sides of Monterey Street beginning from the South side of the Fourth Street
intersection to the North side of the Eighth Street intersection, in Gilroy, California. The work
will be performed at no cost to Gilroy. All transverse joints and the joint between the back of the
curb and the bricks, and locations between the curb and brick, are excluded from the scope of
work.
(d) Release of Security in Lieu of Retention. Within ten (10) business days of
this Agreement being approved by the City Council, Gilroy will authorize the release of the
funds being in Escrow No. 161762 at Heritage Bank of Commerce pursuant to the Escrow
Agreement for Deposit of Securities in Lieu of Cash Retention on Public Works Project dated
March 16,2006 between the City of Gilroy, Golden Bay Construction, Inc., and Heritage Bank
of Commerce.
(e) Indemnification by Golden Bav. Golden Bay will defend, indemnify and
hold Gilroy and its Related Parties (as defined below) harmless from and against any and all
claims, liens, stop notices, demands, obligations, actions, causes of actions, damages, liabilities,
losses, costs or expenses, of any nature whatsoever, which are now asserted or which may be
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asserted in the future, in whatever manner and in whatever forum, by Golden Bay, its owners,
shareholders, alter egos, affiliates, assignees, employees, agents, subcontractors or suppliers, or
by any other subcontractor, supplier, materialmen, company or person, for labor, materials,
overhead and profit, delay, disruption, loss of efficiency and any and all other direct and/or
indirect costs or expenses, or any cost and time impacts, which are now asserted or which may
be asserted in the future, in whatever manner and in whatever forum, based on facts or
circumstances which exist as of the Effective Date of this Agreement, and which arise out of or
relate to the work performed by Golden Bay on the Project, regardless of the merits of such
claims.
(f) Warranty Period. The parties agree that the one-year warranty period
under the Contract Documents has expired except as to any work expressly required by this
Agreement that has not yet been performed.
3. Mutual Release.
3.1 By Gilroy. Subject to the limitations in this paragraph, and the other
covenants and obligations under this Agreement, Gilroy, on behalf of itself, its representatives,
insurers, attorneys, successors, predecessors, affiliates, assignees, assignors, joint venturers,
partners, parents or affiliated entities, subsidiaries, agents, employees, officers, directors,
shareholders, owners or alter egos (collectively referred to as the "Gilroy Related Parties"),
releases Golden Bay and the Golden Bay Related Parties (as defined below) from claims,
demands, causes of actions, or liabilities which arise out of or relate to the facts set forth in the
Recitals, Contract, or the work performed by Golden Bay on the Project. Provided, however,
that this release specifically excludes any rights, claims, demands, causes of action, liabilities, or
damages (hereinafter "Claims") Gilroy now has or may have in the future, whether based in
contract, tort, or otherwise, relating to (a) latent defects in the work performed by Golden Bay on
the Project that are not known by Gilroy to exist as of the Date of this Agreement, (b) any
indemnity obligations owed by Golden Bay to Gilroy with respect to the Project, to the extent
such indemnity obligations actually exist, and/or (c) any Claims which arise because of a breach
of any term of this Agreement by Golden Bay.
3.2 By Golden Bay. Subject to the limitations in this paragraph, Golden
Bay, on behalf of itself, its representatives, insurers, attorneys, successors, predecessors,
affiliates, assignees, assignors, joint venturers, partners, parents or affiliated entities, subsidiaries,
agents, employees, officers, directors, shareholders, owners or alter egos, subcontractors,
suppliers, or sureties (collectively referred to as the "Golden Bay Related Parties"), hereby
releases Gilroy and all of the Gilroy Related Parties from any and all claims, liens, demands,
obligations, actions, causes of action, damages, liabilities, losses, costs or expenses, of any nature
whatsoever, known or unknown, past, present or future, ascertained or unascertained, suspected
or unsuspected, existing or claimed to exist, which Golden Bay now has or may hereafter have
against Gilroy or the Gilroy Related Parties, arising out of or related to the Contract or the
Project. Provided, however, that this release specifically excludes (a) any defenses Golden Bay
may have to any Claim asserted by Gilroy, including without limitation, a Claim for any alleged
latent defects in the work performed by Golden Bay on the Project that are not known by Gilroy
to exist as of the Date of this Agreement; and/or (b) any Claims which arise because of a breach
of any term of this Agreement by Gilroy.
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4. Waiver of Unknown Claims. This Agreement is a full and final release by
Golden Bay and Gilroy solely as to the matters referenced in Paragraph 3 above (collectively
referred to as the "Released Matters"). With respect to those matters covered by the above
releases, the parties hereto, for themselves and their Related Parties, expressly waive any right or
claim of any right to assert hereafter that any Released Matters have, through ignorance,
oversight or error, been omitted from the terms of this Agreement and expressly waive any right
or claim of right they may have under the provisions of California Civil Code Section 1542,
which they understand provides as follows:
A general release does not extend to claims which the creditor does
not know or suspect to exist in his or her favor at the time of
executing the release, which if known by him or her must have
materially affected his or her settlement with the debtor.
It is understood and agreed that the waiver of unknown claims applies only as to those
matters for which a waiver and release has been given, and not to those matters outside the scope
of any waiver and release.
5. Remaining Contract Terms Unmodified. Except as modified by this Agreement,
the Contract shall remain in full force and effect. In the event of any conflict between this
Agreement and the Contract, this Agreement shall govern and control the intent and agreement
of the parties.
6. Fees and Costs. Both Golden Bay and Gilroy agree to be responsible for their
own attorneys' fees and costs incurred in connection with the facts and circumstances leading up
to this Agreement. Provided, however, that if any party to this Agreement commences any
proceeding, at law or in equity, against the other party, which proceeding relates to the
enforcement of this Agreement or the performance of their respective duties and obligations
under this Agreement, the non-prevailing party in such proceeding shall pay to the prevailing
party the prevailing party's reasonable attorneys' fees and other legal fees, expert and consultant
fees and other costs and expenses incurred in connection with such proceeding and those
incurred in connection with the enforcement of any resulting judgment or order. Such post
judgment right to receive attorneys' fees and other legal fees, expert and consultant fees and
other costs and expenses shall be specifically provided in such judgment or order.
7. Representations and Warranties. As an integral and material part of this
Agreement each party represents and warrants to the other party that they are the sole owners of
their Released Matters and that they have not sold, transferred, conveyed, assigned or
hypothecated any of their Released Matters and that this Agreement as so executed constitutes a
legal, valid and binding contractual obligation enforceable against them.
8. Understanding of Agreement. Each party hereto affirms and acknowledges that
each has both read this Agreement and all attachments hereto and thereto (together the
"Documents") and has had an opportunity to have the Documents fully explained by counsel of
choice, that each fully understands and appreciates the words and terms used in the Documents
and their effect, that this is a full and final compromise, release and settlement of the Released
Matters, and that each signs this Agreement of his or her own free will. Each party, and its
respective attorneys, have carefully and fully reviewed and revised, or have had an opportunity
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to revise, the Documents. Accordingly, the normal rule of construction that any ambiguities are
to be resolved against the drafting party shall not be utilized in the interpretation of any of the
Documents.
9. Execution of All Documents. The parties to this Agreement agree to execute any
and all documents necessary to effectuate the terms, conditions, purposes and aims of this
Agreement.
10. Amendment. This Agreement may be amended, or any right or condition
hereunder waived, only by a written instrument signed by the party against whom such an
amendment or waiver is sought to be enforced.
11. Counterpart Signatures. This Agreement may be executed in any number of
counterparts, with the same effect as if all parties have signed the same document, and each such
executed counterpart shall be deemed to be an original instrument. All such executed
counterparts together shall constitute one and the same instrument. True and correct copies or
facsimile transmittals of the executed original may be used in lieu of the original.
12. Benefit of Agreement. Each and every term of this Agreement shall be binding
upon and inure to the benefit of Golden Bay and Gilroy, their successors and assigns and shall
bind and inure to the benefit of those persons and entities described in Paragraph 3 above, which
persons are intended to be beneficiaries of this Agreement.
13. Applicable Law. This Agreement shall be governed by and construed m
accordance with the laws of the State of California.
14. No Admission. This Agreement is the settlement of a disputed claim, and is not
an admission of liability by any party hereto. In particular, and without limitation, neither party
admits that it delayed the Project or that it is responsible for or liable for delay or disruption
damages or liquidated damages in the absence of this Agreement.
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IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the day
and year as indicated below, the last of which shall be the "Effective Date".
Dated: May ~ 20 1 0
TRUCTION, INC.,
Dated: May{ '3, 2010
CITY OF GILROY,
a California municipal corporation
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By: Thomas. Haglund
Its: City Administrator
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