HomeMy WebLinkAbout1998 Ordinance No. 069.
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ORDINANCE NO.ft!/_
SERIES OF 1998
BY AUTHORITY
COUNCIL BILL NO. 60
INTRODUCED BY COUNCIL
MEMBER BRADSHAW
AN ORDINANCE APPROVING A SETTLEMENT OF AND AUTHORIZING THE
SIGNING OF DOCUMENTS FOR THE SETTLEMENT OF GESIN VS. CITY OF
ENGLEWOOD. ET.AL..
WHEREAS, the owner of the property located at 3605 South Bannock Street,
Englewood applied for a building permit to enlarge or remodel the structure; and
WHEREAS, in the course of review it was found that the existing residence
encroached a total of four square feet (4 ') into the City of Englewood's Right-Of-Way for
the City Ditch and any increase in the size of the structure would further encroach into
the Right-Of-Way; and
WHEREAS, the owner sued the City in a quiet title action concerning the property
saying the property was hers and the City was exercising control without due process
of law and the City counterclaimed for a determination of exact boundaries among
other claims; and
WHEREAS, the parties have reached a settlement in the lawsuit in which the City
Quit Claims four square feet (4 ') under the current structure which allows the owner to
maintain the current residence; and
WHEREAS, the City also gives the owner a standard City Ditch License to use
another 1,617 square feet of the Right-Of-Way as lawn only;
NOW, THEREFORE , BE IT ORDAINED BY THE CITY COUNCIL OF THf CITY OF
ENGLEWOOD, COLORADO, AS FOLLOWS:
Section 1. Pursuant to the Settlement Agreement the Englewood City Council
hereby approves the following documents:
License Agreement -attached hereto as Exhibit A ; ""'-
Quit Claim Deed -attached hereto as Exhibit B; and
Mutual Release and Settlement Agreement -attached hereto as Exhibit C.
Section 2. The Mayor is authorized to execute and the City Clerk to attest and
~ Quit Claim Deed and the Mutual Release and Settlement Agreement for and
on behalf of the City of Englewood , Colorado.
Section 3 .. The Director of Utilities and the Chairman of the Englewood Water
and Sewer Board are authorized to execute the License Agreement for and on behalf of
the City of Englewood, Colorado .
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Introduced, read in full, and p assed on first reading on the 21st day of September,
1998.
Published as a Bill for an Ordinance on the 25th day of September, 1998.
Read by title and passed on final reading on the 19th day of October, 1998 .
Published by title as Ordinance No . fr!J.. Series of 1998, on the 23rd day of
October, 1998.
I, Loucrishia A. Ellis, City Clerk of the City of Englewood , Colorado, hereby certify
that the above and foregoing is a t rue copy of the Ordinance pa~sed on final reading
and published by title as Ordinance No. "(p_!/., Series of 1998.
'a.~
Loucrishia A. Ellis
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LICENSE AGREEMENT
TIITS LICENSE AGREEMENT, made and entered into as of the day of
September, 1998, by and between the CITY OF ENGLEWOOD, a municipal corporation of
Colorado, hereinafter referred to as "City" and
I,era ,;1 Gesin a/k/a I .era M Poynter
3605 South Bannock Street, Englewood, Colorado 80110
hereinafter ref erred to as "Licensee, "
WITNESSETH :
The City without any warranty of its title or interest whatsoever, hereby grants the
following license to Licensee for the following :
A parcel of land being a part of the land known as City Ditch, located in a portion of the Northeast
Quarter of the Northwest Quarter of Section 3, Township 5 South , Range 68 West, of the Sixth
Principal Meridian, City of Englewood , County of Arapahoe, State of Colorado, being more
particularly described as follows :
Beginning at the Northeast corne r of Lot 14 , Block 3 of the Englewood Heights Subdivision, said point also
being a point on the Southeast line of said City Ditch ;
l, Thence South 46 °00'00" West, along said Southeast line, a distance of 111.12 feet;
2. Thence South 55°30'00 " West, continuing along said Southeast line , a distance of 53 .49 feet, to a point
on the Northwest line of Lot 12, Block 3 of said Englewood Heights Subdivision;
3 . Thence North 01°18'35" West, leaving said Southeast line of the City Ditch and said Northwest line
of said Lot 12 , a distance of 10 .69 feet, to the intersection of fences;
4. Thence North 50°13 '39 " East, along a fence line, a distance of91.18 feet;
5. Thence North 48°16'45" East, continuing along said fence line, a distance of 19 .99 feet;
6 , Thence North 50°05'48" East, continuing along said fence line, a distance of 49.44 feet;
7, Thence South 11°26'22" East, a distance of 6.68 feet, w the point of Beginning, containing 1,617
square feet, more or less.
The basis of bearings was formed between 2 pin and caps on the Southeast line of said City Ditch, being South
46000'00" West.
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1. Licensee is granted an exclusive license to the Licensed Property subject to the
provisions of this Agreement. In addition, Licensee is granted the following
specific rights subject to all provisions contained in this Agreement; to wit:
a. The existing Residential Structure and/or its foundation located on
lots 13 and 14, Block 3, Englewood, Colorado, (the "Residential
Structure") will not be removed by the City.
b·. The right to maintain and repair the existing Residential Structure
and/or its foundation, within the boundaries of Lots 13 and 14,
Block 3, as they are defined and ·-described in the surveyor's plat
attached hereto as Exhibit A. It is understood and agreed that no
part of the Residential Structure is located on the Licensed
Property.
c. The right to receive a variance from the City for a set back, the purpose of which
is to place additional foundation to the existing strucrure.
d. The right to any use of the Residential Structure, Lots 13 and 14
and Licensed Property as specifically permitted under current R-3
zoning .
2. In granting this License, the City reserves the right to make full use of the
Licensed Property as may be necessary or convenient in the operation of the City
and the City retains all right to operate, maintain, install, repair, remove or
relocate any of its facilities located within the Licensed Property, at any time, and
in such a manner as it deems necessary or convenient . In the event Licensee
makes structural improvements on the Licensed Property and such structural
improvements should interfere with the City's use or operation of the Licensed
Property, at any time hereafter, Licensee shall, upon request by the City at
Licensee's sole expense, immediately relocate, rearrange or remove such
structural improvement so as not to interfere with any such City use ·and to
remove the structural improvement of Licensee when necessary or convenient for .
the City, its successors and assigns.
3. Subject to the provisions contained in paragraphs 1 and 2, the City shall have the
right to maintain, install, repair, remove or relocate the City Ditch or any other
of its facilities or installations within the Licensed Property at any time and in
such manner as the City deems necessary or convenient. The City reserves the
exclusive right to control all easements and installations .
4 . The Licensee shall have the right to maintain and improve the Licensed Property
including, but not limited to, planting and trimming grass and/or bushes,
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fertilization and irrigation, and removal of trash and brush. Licensee is not
permitted to construct any permanent structure(s) or encroach upon the Licensed
Property in a manner not permitted under this License Agreement.
Access to the parcel by City personnel must be maintained by Licensee for
inspection and maintenance.
No construction of permanent structures shall be allowed.
Upon abandonment of any right or privilege herein granted, the right of Licensee
to that extent shall terminate, but its obiigatio,n to indemnify and save harmless
the City, its officers and employees, shall not terminate in any event.
The rights granted Licensee hereunder may not be assigned to subsequent
purchasers of Lots 13 and 14, Block 3, Englewood, Colorado, without the written
consent of the City; however, consent by the City to assignment of this License
may not be unreasonably withheld.
Licensee shall comply with all applicable state or federal laws and ordinances and
all rules, regulations and requirements of any environmental standards and
conditions applicable to the City Ditch or City Right-of-Way. If, as a result of
the Licensee's occupancy of the premises and its operation hereunder, any such
law, ordinance, rule or regulation is violated, Licensee shall protect, save
harmless, defend and indemnify the City from and against any penalties, fines,
costs and expenses including legal fees and court costs incurred by the City,
caused by, resulting from or connected with such violation or violations, and this
License shall terminate immediately. This provision shall not, however, operate
to relieve the City of any liability it may have under any state or federal law for
release of any hazardous material or waste for which the City may be liable.
IN WITNESS WHEREOF, this instrument has been executed as of the day and year first
above written.
APPROVED:
Stewart Fonda
APPROVED AS TO FOR.i\1
CITY OF ENGLEWOOD
acting through and by its
Water and Sewer Board
By:~~~~~~~~~~~~
Chairman
LICENSEE
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QUIT CLATh1 DEED
THIS DEED made this __ day of September, 1998, between the CITY OF
ENGLEWOOD, a municipal corporation, whose address is 3400 South Elati Street, Englewood,
Colorado (hereinafter "Grantor") and Lera M. Poynter, whose address is 3605 South Bannock
Street, Englewood, Colorado (hereinafter "Grantee"):
W I T N E S S E T H:
That the Grantor, for and in consideration for the dismissal of Civil Action No .
97CV3608 styled Lera M. Gesin alk/a Lera M. Poynter v. City of Englewood, et al. and
Settlement Agreement and Release dated __ day of , 1998, and incorporated by
reference herein, the receipt and sufficiency of which is hereby acknowledged, by the presents
does remise, release, sell, convey, and Quit Claim unto Grantee, her successors and assigns
forever all the rights, title, interest, claim and demand which the Granter has in and to the
following described real property, lying and being in the City of Englewood and State of
Colorado, described as follows:
A parcel of land be ing a part of the land known as City Ditch, located in a portion of the Northeast Quarter of the
Northwest Quarter of Section 3, Township 5 South, Range 68 West, of the Sixth Principal Meridian , City of Englewood,
County of Arapahoe , State of Colorado , being more particularly described as follows:
Commencing at the Northeast corner of Lot 14, Block 3 of the Englewood Heights Subdivision, said point also being
a point on the Southeast line of said City Ditch ; Thence South 46 oQQ 'OO" West, along the Southeast line of said City
Ditch and along the Northwest line of said Lot 14, a distance of 61.40 feet , to the True Point of Beginning ;
Thence along the following four (4) courses ;
1.) South 46 oQQ'OO " West, along the Southeast line of said City Ditch, a distance of 2 .00 feet;
2.) North 44 oQO'OO " West , leaving last said Southeast line , a distance of 2 .00 feet;
3 .) North 46 oQQ'OO" East, along a line parallel with said Southeast line, a distance of2.00 feet;
4 .) South 44 oQQ 'OO " East, a distance of2 .00 feet, to the True Point of Beginning, containing 4 square feet, more or less.
The basis of bearings was formed between 2 pin and caps on the Southeast line of said City Ditch, being South
46 oQQ 'OO " West .
The above described parcel is conveyed for purposes of maintaining the foundation to the
residential structure at 3605 South Bannock Street, Englewood, Colorado . If and when the
parcel ceases to be used for this purpose it shall immediately revert to the City of Englewood,
State of Colorado .
TO HA VE AND TO HOLD the same, together with all and singular the appurtenances
and privileges thereunder belonging or in anywise thereto appertaining, and all the estate, right,
title, interest and claim whatsoever, of the Grantor, either in law or equity, to the only proper
use, benefit and behoof of the Grantees, their successors and assigns forever .
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IN WITNESS WHEREOF, the Gran.tor has executed this deed on the date set forth
above.
TIIE CITY OF ENGLEWOOD
By:_· ___________ _
Thomas J. Burns, 11ayor
AITEST:
Loucrishia A. Ellis, City Clerk
STATE OF COLORADO )
) SS.
CITY OF ENGLEWOOD )
Acknowledged, subscribed, and sworn to before me this day of
1998, by Thomas J. Burns , as Mayor ------of_th_e_C_i_ty
of Englewood .
WITNESS my hand and official seal.
My commission expires :
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Notary Public
Address
AFfER RECORDING PLEASE MAIL TO :
The City of Englewood
3400 South Elati Street
Englewood, Colorado 80110-2304
Attn: City Attorney
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EXHIBIT
SCALE : 1"= 20'
s 55·30·00" w
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AREA=
4 SQ . FT .
POST
2 STORY
BRICK & FRAME
HOUSE
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LINE SEARING DISTANCE
L1 s 45·00·00" w 2.00·
L2 N 44·00·00" w 2.00·
L3 N 46"00'00 " E 2.00·
L4 S 44·00·00" E 2.00·
ROCKY MOUNTAlN CONSULTANTS. INC.
LOT 14
N 8 ·75 ' " I="
83 .75"
2.o·x5. 7'
PLANTER
LCT 13
LOT 12
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8301 E. Prentice A•c . Suite 101 Enqlcwood. CO 80111 (303) 741-6000 FIJ. (303) 741-6106
EXH3.DWC
.1nA •1n ?i.A? nn7 oo OATE 06/18/98
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RE'llSED 0151215 /98
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l\1UTUAL RELEASE AND SETILEMENT AGREEMENT
This Mutual Release and Settlement Agreement made and entered into this day of
September, 1998 , by and between Lera M. Gesin a/kla Lera M. Poynter ("Plaintiff") and The
City of Englewood, ("Defendant The City of Englewood").
A.
RECITALS
Plaintiff filed a Complaint against several defendants in the Arapahoe County
District Court, Civil Action No. 97 CV 3608 , entitled Lera M . Gesin a/kl a Lera
M . Poynter v. Ciry of Englewood, et al. (the "Complaint"), which Complaint
arose out of a dispute concerning ownership and title to a parcel of real property
located within the City of Englewood, within an area commonly known as the
"Englewood City Ditch " or "Right-of-Wa y " (hereinafter referred to as the City
Right-of-Way). In the Complaint, Plaintiff sought a judicial declaration under
C .R.C.P . 105 that Plaintiff was the exclusive owner and exclusive title holder to
a specific parcel of property contained within the City Right-of-Way. Defendant
The City of Englewood filed certain counterclaims for trespass and declaratory
relief under C .R.C.P . 57 as part of this civil action .
B. Upon the terms and conditions se t forth below, the parties desire to enter into this
Mutual Release and Settlement Agreement in order to discharge all claims of
Plaintiff which are, or might have been, the subject matter of the Complaint, and
all claims of Defendant The City of Englewood, which are the subject matter of
the Counterclaims contained in the above described Civil Action.
AGREEMENT
The parties agree as follows:
1. 0 Release and Discharge
1.1 In consideration of the execution for a License Agreement and Quit Claim Deed
as set forth in Section 2, Plaintiff hereby completely releases and forever
discharges Defendants from any and all past, present or future claims, demands,
obligations, actions, causes of action, rights, damages, costs, losses of services,
expenses and compensation of any nature whatsoever, whether based on a tort,
contract or other theory of recovery, which the Plaintiff now has, or which may
hereafter accrue or otherwise be acquired , on account of, or may in any way
grow out of, or which are, or which could be , the subject of th~ Complaint (an_d
all related pleadings).
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1.2 This release and discharge shall also apply to Defendants' past, present and future
officers, directors, council persons, attorneys, agents, servants, representatives,
employees, subsidiaries, affiliates, predecessors and successors in interest, and
assigns and all other persons, firms or corporations with whom any of the former
have been, are now, or may hereafter be affiliated.
1.3 The Plaintiff acknowledges and agrees that the release and discharge set forth
above is a general release . Plaintiff expressly waives and assumes the risk of any
and all claims which exist as of this date, but of which the Plaintiff does not
know or suspect to exist, whether through ignorance, oversight, error,
negligence, or otherwise, and which, if known, would materially affect Plaintiff's
decision to enter into this Mutual Release and Settlement Agreement .
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1.4 It is understood and agreed to by Plaintiff that this settlement is a compromise of
a disputed claim.
1.5 This release shall be a fully binding and complete settlement among the Plaintiff
and Defendant, and its heirs , assigns, and successors, forever.
2. 0 Consideration
2.1 In exchange for consideration described herein. Defendant Cirv of Englewood
agrees to the following :
a. Contemporaneously with the execution of this Mutual Release and Settlement
Agreement, Plaintiff and Defendant The City of Englewood, have executed a License Ag reement
providing that Plaintiff shall have the exclusive use of a parcel of the City Right-of-Way
property adjacent to her property , and in accord with the terms of the License Agreement. The
licensed property is described and set forth in the License Agreement attached to this Release
as "Exhibit A" and is incorporated by reference as if fully set forth herein.
b . Contemporaneously with the execution of this Mutual Release and Settlement
Agreement , Defendant The City of Englewood shall execute a Quit Claim Deed granting
ownership of a parcel of real property to Plaintiff for the purposes of reinforcing existing
foundation to the current residential structure. A copy of the Quit Claim Deed is attached hereto
as Exhibit "B" and is incorporated by reference as if fully set forth herein.
c. Dismissal with prejudice of all counterclaims or causes of action which could have
been pleaded against Plaintiff, in a lawsuit now filed in the Arapahoe County District Court for
the District of Colorado, under Case No. 97 CV 3608 entitled Lera M. Gesin alk/a Lera M.
Poynter v. City of Englewood, et al .
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2.2 In exchange for consideration described herein. Plaintiff agrees to the following:
a. Dismissal with prejudice of all claims and causes of actions which could have been
pleaded against the City, in a lawsuit now filed in the Arapahoe County District Court for the
District of Colorado, under Case No. 97 CV 3608 entitled Lera M. Gesin a!k!a Lera M.
Poynter v. City of Englewood, et al.
3.0 Attorney's Fees
Each party hereto shall bear all attorney's fees and costs arising from the actions of its own
counsel in connection with the Complaint, this Mutual Release and Settlement Agreement and
the matters and documents referred to herein , the filing of a Stipulated Motion of Dismissal of
the Complaint, and all related matters .
4.0 Delivery of Dismissal Without Prejudice
Concurrently with the execution of this Mutual Release and Settlement Agreement, Plaintiff shall
deliver to counsel for the Defendant an executed Stipulated Motion for Dismissal With Prejudice
of the Complaint. Plaintiff hereby authorizes counsel for the Defendant to file said Motion with
the Court and enter it as a matter of record.
5 .0 Representation of Comprehension of Document
In entering into this Mutual Release and Settlement Agreement, Plaintiff and Defendant represent
that each of them has relied upon the advice of individuals and/or attorneys, who are individuals
of their own choice, concerning the legal consequences of this Mutual Release and Settlement
Agreement; that the terms of this Mutual Release and Settlement Agreement have been
completely read by Plaintiff and Defendant; and that the terms of this Mutual Release and
Settlement Agreement are fully understood and voluntarily accepted by Plaintiff and Defendant.
6. 0 Governing Law
This Mutual Release and Settlement Agreement shall be construed and interpreted in accordance
with the laws of the State of Colorado .
7.0 Entire Agreement and Successors in Interest
This Mutual Release and Settlement Agreement contains the entire agreement between the
Plaintiff and the Defendant with regard to the matters set forth in it and shall be binding upon
and enure to the benefit of the executors, administrators, personal representatives, heirs,
successors and assigns of each .
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8.0 Effectiveness
This Mutual Release and Settlement Agreement shall become effective immediately following
execution by Plaintiff and Defendant, the City of Englewood.
STATE OF COLORADO
COUNTY OF ARAPAHOE
Lera M. Gesin, Plaintiff
By:
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Subscribed and sworn to before me on this __ day of September, 1998 , by
WITNESS my hand and official seal.
My Commission expires: --------
Notary Public
Lera M. Poynter, Plaintiff
Lera M. Poynter
STATE OF COLORADO
COUNTY OF ARAPAHOE
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Subscribed and sworn to before me on this __ day of September, 1998, by
WITNESS my hand and official seal.
My Commission expires: --------
Notary Public
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The City of Englewood, Defendant
STATE OF COLORADO
COUNTY OF ARAPAHOE
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Thomas J. Burns, Mayor
Subscribed and sworn to before me on this __ day of September, 1998, by
Thomas J. Burns as Mayor. · -
WITNESS my hand and official seal.
My Commission expires: --------
Notary Public
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COUNCIL COMMUNICATION
Date Agenda Item Subject
Gesin Settlement -
September 21, 1998 11 a ii 3605 S. Bannock Stree t
Initiated By Staff Source
Utilities Department Stewart Fonda, Director of Utilities
COUNCIL GOAL AND PREVIOUS COUNCIL ACTION
Council authorized the City Attorney to represent City Council in the lawsuit filed by Lera Gesin.
RECOMMENDED ACTION
Council approval of the Quit Claim Deed, License Agreement and Mutual Release and Settlement
Agreement from Lera Gesin.
BACKGROUND, ANALYSIS, AND ALTERNATIVES IDENTIFIED
Mrs. Gesin originally filed for a building permit approximately one year ago to build an addition onto her
house at 3605 S. Bannock St. The addition would have encroached into Englewood's City Ditch right-
of-way. The northwest corner of her house encroaches four square feet into the City Ditch right-of-
way. The City denied her request whereupon she filed suit against the City to allow the proposed
addition.
The suit was mediated at Arapahoe County District Court and the above listed documents a re the
result of the mediation. Englewood is proposing to quit claim Mrs. Gesin four square feet of City Ditch
right-of-way to allow room for improvements to her existing residence. No further expansion will be
allowed. The License Agreement will allow her to use and maintain the City Ditch right-of-way as part
of her back yard, but no permanent improvements may be constructed in this area. The Mutual
Release and Settlement Agreement is the final settlement that was agreed to by all parties.
FINANCIAL IMPACT
None.
LIST OF ATTACHMENTS
Ordinance
Quit Claim Deed, License Agreement and Mutual Release and Settlemen t .