1994-0221_NEGRETE , CARLOS_Settlemeng Agr AddendumADDENDUM TO SETTLEMENT AGREEMENT AND MUTUAL RELEASE ENTERED
INTO BETWEEN CARLOS NEGRETE, COMMITTEE TO RESTORE INTEGRITY
IN SAN JUAN CAPISTRANO, THE CITY OF SAN JUAN CAPISTRANO, SAN
JUAN CAPISTRANO COMMUNITY REDEVELOPMENT AGENCY, GARY HAUSDORFER,
KENNETH FRIESS, ANTHONY BLAND, PHILIP SCHWARTZE, DAVID BENTZ,
GEPHARD DURENBERGER, STEPHEN JULIAN AND GRAHAM & JAMES
The terms and conditions of the above -referenced agreement are
incorporated herein by reference. The following addendum is added
at page 5 at the end of paragraph 4:
However, under no circumstances shall the City of San Juan
Capistrano; Stephen Julian; San Juan Capistrano Community
Redevelopment Agency; Gary Hausdorfer; Kenneth Friess; Anthony
Bland; Philip Schwartze; David Bentz; Lawrence Bucheim; Gephard
Durenberger; and Graham & James be entitled to enforce any orders
and judgments for costs and attorney's fees entered in the
Taxpayer's Action entitled Committee to RPS or Int-arity in San
Juan Capistrano. et a1. v. The City of San Juan Capistrano,
St-ephen B. Julian. et Al., Orange County Superior Court Case No.
65-27-09 against Negrete's insurers, Truck Insurance Exchange
and/or Fire Insurance Exchange and/or any other Farmer's entity.
All such claims against Truck Insurance Exchange and/or Fire
Insurance Exchange and/or any other Farmer's entity are forever
waived and discharged. The City of San Juan Capistrano; San Juan
Capistrano Community Redevelopment Agency; Gary Hausdorfer;
Kenneth Friess; Anthony Bland; Philip Schwartze; David Bentz;
Lawrence Bucheim; Gephard Durenberger; and Graham & James warrant
that they have made no assignment, voluntarily or involuntarily of
all or any part of their claim or potential claims to Truck
Insurance Exchange and/or Fire Insurance Exchange and/or any other
Farmer's entity to any other persons or entities.
Dated: February Z/, 1994
Dated: February Z/, 1994
Dated: February /(, 1994
COMMITTEE TO RESTORE INTEGRITY IN
SAN JUAN CAPISTRANO
By: .=�.y=
Carlos Negr e
THE CITY OF SAN JUAN CAPISTRANO
By: _,., zz__ _,_/ �__
Ma r Coll am ell
SIGNATURES CONTINUED ON NEXT PAGE
Dated: February /6, 1994
Dated: February /?, 1994
Dated: February 1994
Dated: FebruaryZ3,, 1994
Dated: February /$,, 1994
Dated: February , 1994
Dated: February 3, 1994
M Oocz'
Dated: F bz4Lajr 1994
0
SAN JUAN CAPISTRANO COMMUNITY
REDEVELOPMENT AGENCY
j � >��7
By:
Chairmaif Carolyn Nash
By:,i'\
"Ke neth E. Priess
By:
zdLz dv�A.
Anthony Bland
By:
Philip Schwartze
l
By:
David Bentz
s
By:
i'16(arence Euche(im
Gerhar Durenberger
L'
SIGNATURES CONTINUED ON NEXT PAGE
-2-
0
Dated: February , 1994
Dated: February /,i, 1994
Dated: February 118, 1994
Dated: FebruaryX-4,, 1994
Dated: February GI, 1994
is
ZW—
GRAHAM & JAMES
By:
MOVED AS FO & CONTENT:
By:
Kenneth ulian, Attorney for
Stephen B. Julian
APPROVED AS TO FORM & CONTENT:
By: LZI
PcKil L. Gale, A for for the
City of San Juan Capistrano
APPROVED AS TO FORM & CONTENT:
By:
Jeffrey
Carlos
✓G
-3-
Attorney
0 0
SETTLEMENT AGREEMENT AND MUTUAL RELEASE
WHEREAS, on or about March 19, 1991, a lawsuit (Orange
County Superior Court Case Number 65-27-09) was filed by
plaintiffs, Committee to Restore Integrity in San Juan
Capistrano, Adele Keithhahn, Julian Keithhahn, Timothy Byers and
Carlos F. Negrete (hereinafter "Plaintiffs") against defendants,
The City of San Juan Capistrano, Gary L. Hausdorfer, Kenneth E.
Friess, Lawrence Buchheim, Anthony L. Bland, Philip Schwartze,
Stephen B. Julian, David Bentz and, later, Gephard R. Durenberger
(hereinafter "Defendants"); and
WHEREAS, a judgment has been entered in Orange County
Superior Court Case Number 65-27-09 (the "Taxpayer's Action") in
favor of Defendants on all causes of action and awarding certain
attorneys' fees and costs to Defendants, which judgment has been
appealed as described herein, and which judgment has been the
subject of Defendants' motion for additional attorneys' fees and
costs, which motion was granted by the Superior Court; and
WHEREAS, a defense has been provided to all Defendants in
this case by the City of San Juan Capistrano (hereinafter
"City$') ; and
WHEREAS, various aspects of the lawsuit described above have
become the subject of appeal in the following matters:
1) Fourth Appellate District Court of Appeal Case Number 4
Civil No. G013359;
2) Fourth Appellate District Court of Appeal Case Number 4
Civil No. G014188;
3) Fourth Appellate District Court of Appeal Case Number 4
Civil No. G013726;
4) Fourth Appellate District Court of Appeal Case Number 4
Civil No. GO14413;
WHEREAS, plaintiff, Carlos F. Negrete, has filed subsequent
related litigation entitled:
1) Carlos F. Negrete v. City of San Juan Capistrano,
San Juan Capistrano Community Redevelopment Agency and
Genhard R. Durenberger (Orange County Superior Court Case
Number 70-74-10);
0:\USR\KBJ\PLD\125457
0 0
2) Carlos F. Nearete v. City of San Juan Capistrano and
San Juan Capistrano Community Redevelopment Agency (Orange
County Superior Court Case Number 70-82-62);
3) Carlos F. Nearete V. Kenneth Friess (Orange County
Superior Court Case Number 70-27-08); and
4) Carlos F. Nearete v. City of San Juan Capistrano. etc..
et al. (United States District Court, Central, Case
Number SACV-93-1016-GLT(RWRX); and
WHEREAS, subject to the terms of this Agreement, it is the
intention of the parties to enter into a settlement agreement
terminating all pending litigation, claims, appeals and
threatened or proposed litigation between these parties, now, and
for not less than five years from the date of this Agreement;
NOW, THEREFORE, in consideration of the mutual promises,
releases and dismissals contained herein, Carlos F. Negrete and
the Committee to Restore Integrity in San Juan Capistrano
(hereinafter "Negrete") and the City of San Juan Capistrano (the
"City"), the San Juan Capistrano Community Redevelopment Agency,
Gary L. Hausdorfer, Kenneth E. Friess, Lawrence Buchheim,
Anthony L. Bland, Philip Schwartze, David Bentz, Kenneth E.
Friess, Lawrence Buchheim, Anthony L. Bland, Philip Schwartze,
David Bentz, Stephen B. Julian and Gephard R. Durenberger
(hereinafter "City Defendants"), do hereby voluntarily and
knowingly execute this document (the "Agreement").
OBLIGATIONS OF NEGRETE
1. Negrete agrees to dismiss with prejudice all pending
lawsuits and appeals against the City Defendants and, to the
extent applicable, all present and former elected and appointed
officials and employees and all agents thereof, as follows:
A. All pending appeals resulting from Committee to Restore
Integrity etc et al v City of San Juan Capistrano et
al., Orange County Court Case No. 65-27-09, including, but
not limited to:
1) Fourth Appellate District Court of Appeal Case
Number 4 Civil No. G013359;
2) Fourth Appellate District Court of Appeal Case
Number 4 Civil No. GO14188;
3) Fourth Appellate District Court of Appeal Case
Number 4 Civil No. G013726;
-2-
0:\USR\K8J\PLD\125451
0
0
4) Fourth Appellate District Court of Appeal Case
Number 4 Civil No. G014413;
B. Carlos F. Nearete v. City of San Juan Capistrano, Sa
Juan Capistrano Community Redevelopment Aaencv and
Gep and R. Durenberger (Orange County Superior Court Case
Number 70-74-10); and
C.
Juan Capistrano Community Redevelopment Agency (Orange
County Superior Court Case Number 70-82-62); and
D. Carlos F. Negrete V. Kenneth Friess (Orange County
Superior Court Case Number 70-27-08); and
E. Fourth Appellate District Court of Appeal Case Number 4
Civil Number G014848; and
F. Carlos F. Negrete v._ Citv of San Juan Capistrano, et
al. (United States District Court, Central, Case
Number SACV-93-1016-GLT(RWRX); and
G. Any other case now pending on appeal, or otherwise
contemplated or threatened, whether served or unserved,
against City Defendants and present or former City officers,
employees and agents, except the case of Richard B. Hassett
Maddaloni, Tarbell Realtors, et a1., Orange County Superior
Court Case No. 70-29-86 (the "Hassett Case"), which shall
not be affected by this Agreement unless the case is amended
beyond its present form and in a manner affecting the rights
and obligations covered by this Agreement.
2. It is the intention of the parties to this Agreement
that this shall bring an end to litigation and claims between
Negrete and the City and all City Defendants and bring peace to
the community of San Juan Capistrano as between these Plaintiffs
and City Defendants for a period of not less than five (5) years
from the date of execution of this Agreement.
2.1 For a period of five (5) years, Negrete agrees to
neither personally institute nor represent as an attorney any
other person or entity in any taxpayer actions or lawsuits of any
kind involving official City or Agency action, against the City,
the Agency, its officers, employees, directors, assigns,
administrators, agents or representatives (hereinafter "City
Agents") acting in an official capacity or within the course and
scope of employment with the City or the Agency, except for (1)
actions by Negrete in his individual capacity against the City
for breach of any written contract that may be entered into
-3-
0:\USR\KBJ\PLD\125451
between Negrete and the City, (2) actions by Negrete in his
individual capacity against the City or City Agents for any
personal physical injury, including defamation, or physical
damage to real or personal property that may be caused by City
Agents, (3) actions brought by Negrete as counsel on behalf of
any person or entity for breach of a contract involving real
property between a person or entity and the City, and (4) actions
brought by Negrete as counsel on behalf of any person or entity
for physical personal injury or physical damage to real or
personal property that may be caused by the City or City Agents
(the "Covenant Not To Sue").
2.2 In entering into this Agreement, and specifically
Section 2.1 above, the Parties hereto specifically recognize,
have considered, and acknowledge the requirements and obligations
of California Rules of Professional Conduct, Rule 1-500, which is
entitled "Agreements Restricting a Member's Practice" and
provides in pertinent part that:
"A member shall not be a party to or
participate in offering or making an
agreement, whether in connection with the
settlement of a lawsuit or otherwise, if the
agreement restricts the right of a member to
practice law..."
Nothing in this Agreement, however, including, but not
limited to, the provisions of Section 2.1 above, is intended by
any of the parties, nor shall it in any way be construed as
limiting or prohibiting in any way, any right or authority that
Negrete may possess to institute any lawsuit against the City,
the Agency or City Agents, either personally or as an attorney on
behalf of any other person or entity. No provision of this
Agreement, including the provisions of Section 2.1, shall be
construed as limiting or prohibiting in any way Negrete's right,
license or authority to practice law in any way or in any manner
in which he might otherwise be authorized or licensed, including,
but not limited to, representing any individual or entity in
taxpayer actions against the City, the Agency or City Agents.
Rather, by this Agreement, Negrete, the City and the Agency, are
agreeing and making the economic determination that for as long
as Negrete abstains from exercising his above-described rights
during the five-year period following the execution of this
Agreement, the City shall not collect or enforce the Attorney's
Fee Orders entered in the Taxpayer's Action, and that such an
agreement between the parties hereto is reasonable, economically
sound and represents a reasoned balance between the competing
interests and ends of Negrete and the City.
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9 0
OBLIGATIONS OF THE DEFENDANTS
3. City Defendants agree to enter into a stipulation for
the dismissal with prejudice of all pending lawsuits, except the
Taxpayer's Action, and appeals against the City of San Juan
Capistrano, the San Juan Capistrano Community Redevelopment
Agency and all present and former elected and appointed officials
and employees, and all agents thereof, as identified above in
this Agreement.
4. City Defendants hereby expressly release and discharge
Negrete and his counsel from any and all claims, judgments or
causes of action which they may have for attorneys' fees, costs,
reimbursements or other expenditures resulting from the
litigation described in this Agreement, whether known or unknown,
pending or prospective, at the time of the execution of this
Agreement, including claims for attorneys' fees and costs awarded
in the Taxpayer's Action, except that the City's release of
Negrete shall be effective only if, and for so long as, Negrete
abides by the Covenant Not To Sue set fourth in Paragraph 2.1
herein. In the event Negrete breaches the Covenant Not To Sue,
the City's release and discharge of Negrete shall be considered
null and void and Negrete acknowledges that, in that event, the
orders and judgments for Costs and Attorney's Fee entered in the
Taxpayer's Action shall become fully valid and enforceable, and
the City thereafter can enforce all of its rights against
Negrete, including enforcement of those orders and judgments. In
this regard, Julian hereby expressly assigns to the City all of
his rights and interest in the Order awarding attorneys' fees and
costs in the Taxpayer's Action.
5. In the event of any breach by City Defendants of the
terms and conditions of this Agreement, the foregoing covenant
shall constitute a waiver by City Defendants of any right to
recover any such claims, judgments or causes of action for
attorneys' fees, costs reimbursements or expenditures resulting
from the litigation described in this Agreement.
6. Defendant, Stephen B. Julian, and the law firm of
Graham & James, his attorneys of record, agree to waive all
outstanding fees in the litigation described herein (both
disputed and undisputed) due from the City in the amount of
$48,790.51, and City agrees to pay outstanding itemized expenses
of $1,076.76 in full and complete settlement of any and all
remaining defense obligations of City to Defendant Julian for
litigation or claims covered by this Agreement. The City further
agrees to continue to defend and indemnify Julian in the Hassett
Case and to abide by the terms of the Severance Agreement, dated
October 15, 1992, between Julian and the City.
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0:\USR\KBJ\PLD\125451
0
MUTUAL OBLIGATIONS
0
7. Except as set forth in Paragraphs 2.1, 4 and 6 herein,
the parties hereto, and each of them, for their respective
principals, partners and joint ventures, affiliates, insurers,
successors and assigns, do hereby fully and irrevocably release,
discharge and acquit each other, including all Plaintiffs and all
Defendants in all actions and claims described herein, including,
but not limited to the City of San Juan Capistrano, the San Juan
Capistrano Community Redevelopment Agency, Gary L. Hausdorfer,
Kenneth E. Friess, Lawrence Buchheim, Anthony L. Bland, Philip
Schwartze, Stephen B. Julian, David Bentz, Gephard R. Durenberger
and all other present and former elected and appointed officials,
employees, attorneys and agents thereof, as well as, to the
extent applicable, each other's respective past, present and
future officers, directors, partners, employees, agents, joint
ventures, affiliates, representatives, subsidiaries, parent and
affiliated corporations, servants, heirs, administrators,
executors, predecessors, successors, attorneys and assigns
(hereinafter "Related Persons"), jointly and severally, of, from
and against any and all rights, claims, debts, demands, acts,
agreements, liabilities, obligations, damages, costs, fees
(including without limitation, those of attorneys), expenses,
actions and/or causes of action of every nature, character, type
and description, for injuries, damages, losses to persons or
property, real or personal, injury to reputation, contractual
damages or obligations, waste or misappropriation, or any other
claim or cause of action, whether known or unknown, foreseen or
unforeseen, suspected or unsuspected, patent or latent, which the
parties hereto, or any of them, now own or hold, have at any time
heretofore owned or held, or may at any time hereafter own or
hold, against each other or each other's Related Persons, which
arise out of or relate to any matter or issue connected in any
way to the claims or litigation which is the subject of this
settlement. Except as set fourth in Paragraphs 2.1, 4 and 6 of
this Agreement, it is the intent of the parties that this
constitutes a General Release.
S. The parties to this Agreement make no representations
or admissions of liability or misconduct regarding the
allegations contained in the complaints or claims described
herein.
9. The parties certify that they have read Section 1542 of
the California Civil Code, set forth below, and hereby waive the
application of Section 1542 to this Agreement and the claims and
causes of action described herein:
-6-
0:\USR\KBJ\PLD\125451
0 0
"A general release does not extend
to claims which the creditor does
not know or suspect to exist in his
favor at the time of executing the
release, which if known by him must
have materially affected his
settlement with the debtor."
10. Negrete and City Defendants agree that a press release
shall accompany the public release of this Agreement in the form
attached hereto as Exhibit "A". No other press release or
representation to the media shall be made with respect to the
subject matter of this Agreement or the litigation referenced
herein.
11. Negrete and City Defendants agree that if any portion
of this Agreement shall be found to be unlawful by a court or
tribunal of law, that it shall be severable from the remaining
portions of this Agreement, and the remainder of this Agreement
shall continue to be binding and enforceable upon each party
hereto.
12. The parties represent and warrant that the persons
executing this Agreement are fully authorized to do so.
Plaintiff, Carlos F. Negrete represents and warrants further that
he is fully authorized to execute this Agreement on behalf of the
Committee to Restore Integrity in San Juan Capistrano. The
parties warrant that the execution and performance of this
Agreement does not contravene any laws, regulations or
contractual restrictions applicable to or binding upon the
parties. Additionally, the parties each represent and warrant
that they have not assigned or otherwise transferred to any
person or entity any of the claims released hereunder.
13. This Agreement reflects the entire agreement between
the parties relating to the subject discussed herein and
supersedes all prior or contemporaneous oral or written
understandings, statements, representations and promises
regarding these subjects and shall constitute the only valid,
binding and enforceable agreement among them. The parties
represent and warrant that no statements or representations,
other than the statements or representations contained in this
Agreement, have induced their assent to this Agreement.
14. Any modification, alteration or amendment to this
Agreement shall be void and of no force and effect unless it is
in writing and signed by Negrete and the City. This Agreement
shall be binding on and inure to the benefit of the parties and
their respective heirs, representatives, successors and assigns.
-7-
0:\USR\KBJ\PLD\125451
0
15. Negrete and City Defendants acknowledge that they have
been advised by legal counsel in connection with this Agreement
and execute this Agreement voluntarily.
16. If any action in law or equity is necessary to enforce
the terms of this Agreement, the prevailing party shall be
entitled to recover costs, including reasonable attorneys' fees.
17. This Agreement may be executed in one or more
counterparts.
IN WITNESS WHEREOF, this Agreement has been executed by the
undersigned on the dates below indicated:
Dated: jr,7Fs Z , 1994
Dated: F0. 4 , 1994
Dated: oil , 1994
Dated:
, 1994
Dated: , 1994
Dated:
O:W5R\K8J\PLD\125451
, 1994 'Y`
COMMITTEE TO RESTORE INTEGRITY IN
SAN JUAN CAPISTRANO
By:
Carlos F. N e e
THE CITY OF SAN JUAN CAPISTRANO
MayoCollen Campb 1l
SAN JUAN CAPISTRANO COMMUNITY
REDEVELOPMENT AGENCY
-8-
Carolyn Nash
L.1Hausdorfer
. Fr
L,
Dated:ZS / l` , 1994
Dated: " LZ , 1994
Dated: , 1994
Dated: -� — I . 1994 �
Dated: . 1994
Dated: 2 , 1994
Dated: -?I/7 1994
Dated: 02 1994
T
0:\USR\KBJ\PLD\125451
0
David Bentz
FR. Duren huger
B. Jul
GRAHAM & JAMES
B. Julian
APPROVED AS TO FORM:
Paul L. Gale, Attorney for the
Ytyf San JuanCaapp7is%t/Jr�ano
RENCE BgZHH
0
Dated:
1994
Dated: LLZ , 1994
Dated: ! % , 1994
Dated:
F4*x-I
Dated: , 1994
Dated: L/2 , 1994
Dated:
. 1994
0
Anthony L. Bland
Philip 4chwartze
//,
David Bentz
Gephard R. Durenberger
Stephen B. Julian
GRAHAM & JAMES
B. Julian
APPROVED Ag -TO FORM:
Paul L. Gale, Attorney for the
City of San Juan Capistrano
-9-
0:\USR\13J\PLD\725451
0 9
Exhibit A
JOINT PRESS RELEASE
After 34 months of litigation, and approximately a million
dollars of City funds spent for attorneys' fees and costs, Carlos
Negrete and the City of San Juan Capistrano have finally agreed
to settle the host of lawsuits between them.
The agreement calls for Negrete to dismiss five lawsuits filed by
him against the City and present and former City officials,
including five appeals.
Most of the City officials targeted by the original lawsuit are
no longer with the City. The City prevailed in the trial Court.
Negrete Appealed. Both sides cited the extreme cost of the
litigation as the principal reason for the settlement agreement.
Dated: 1cf0- 2 1994
Carlos Negrete
THE CITY OF SAN JUAN CAPISTRANO
By: 1),�4.z dait
Its: RICHARD K. DENHALTER
-lo-
0:\USR\KBJ\PLD\125451
COUGLAS C BERARD
OLIVIA O BISSELL
STERNA N 5 COMN
ROBERT ENDERS. JR
PAUL F FIGLER
STEVEN M GENTRY
LEON J GLADSTONE
LLIAM J. GLAZER
DIANA F GRILLI
JAMES F MENSHALL, JR
CHARLES M KAHN
GARY M KLEIN
JUNE E. KREISEL
LANCE A —BELLE
ALAN MLAZAR
MELODY S. MOSLEY
JON M055
MICHAEL J AIKEN
GALE A AMATO
SUI REENG BANKI
AURA FARREL BUCHER
T1A
aI CJ. CAMPBELL
MOTHY J CHAPMAN
TERESA R. CORDOVA
RENEE C O'AGOSTINO
SAMUEL M DANSKIN
DAVID BEZRA
GARY CANCMROW
THOMAS F HALL
ERIC 8JOHNSON
SUSANNE BERRY JOHNSON
ANN K JOHNSTON
RICHARD ONAPP
J05EPU P KOC NIG
STERN EN H KUKTA
NANCY 5. LAMBRECMT
• LAW OFFICES .
BERGER, KAHN, SHAFTON, MOSS,
FIGLER, SIMON S, GLADSTONE
A PROFESSIONAL CORPORATION
TRICK E. NAUGHTON
ROBERT W. NELMS
TIMOTHY A NICM OLSON
TERESA RANSOM PONDER
DOUGLAS B. POWRIE
ERIC N. RIEZMAN
BETH 5 SCHIRALLI
LORI D. SCROTA
ANTHONY E SHAFTON
MARTINA A. SILAS
CRAIG S51
MON
SMERMAN M SPITZ
JEFFREY A SWEDO
ROGER M VOSBURG
BRUCE M WARREN
KENNETH 5 WOLF
CATHERINE K LATEMPA
TRACEY L LOWRY
CAROLYN A MATHEWS
ROBERT W HELM
HILLARY 5 MEISELS
GARTH UR NEMESES
MARGARET R MIGLIETTA
SHERILYN LEARNED O'DELL
BETH A PALMER
JILL K PETERSON
DANE E POWRIE
MARK M. SENIOR
STEVEN H SILVERMAN
JEFFREY M SPURLOCR
ROBERTA S. TAYLOR
SARA SCHWAB TRASK
SHERYL A, WEINBERGER
MICHAEL R WIPPLER
OF COUNSEL
PAUL 5. BERGER
JAMES 9. KRUG
KENJI MACHIOA, PC
JAMBOREE CENTER
2 PARK PLAZA, SUITE 650
IRVINE, CALIFORNIA 92714-8516
MAILING ADDRESS
P O. BO% 1969♦
IRVINE, CALIFORNIA 92713-9496
(714) 474-1680
TELECORIER 17141 474-7265
March 2, 1994
City of San Juan Capistrano
32400 Paseo Adelanto
San Juan Capistrano, CA 92675
WILLIAM BERGER (1903-19741
LOS ANGELES COUNTY C
4215 GLENCOE AVENUE
2N^ FLOOR
MARINA GEL REY, CALIFORNIA 90292-5893
131 OI 821-9000
TELECOPIER 13101 578-6176
SAN FRANC15CO BAY AREA O -`ICE
101 LUCAS VALLEY ROAD
SUITE 300
SAN R FAEL, CALIFORNIA 94903
14151 472-2900
TELECOPIER 14131 472-5892
SAN DIEGO COUNTY C°F10E
.01 WEST BROADWAY
SUITE 1950
SAN DIEGO, CALIFORNIA 92101
16181 236-8602
TELECOPIER 16191 236-0812
2358
OUR FILE NO
Attn.: Suzanne Ramsey
RE: Insured Carlos Negrete
Policy #Is: 60089 14 26 (Office Special Sentinel
Package Super Policy; and
60089 14 32 (Personal _mbrella Liability
Policy)
Claim No. X7-5858
Dates/Loss: 1-8-91 and 1-15-91
Committee to Restore Integrity, etc., et a1. v. The City
of San Juan Capistrano, et al., Defendants and Cross
Action Stephen S. Julian, Cross -Complainant v. Carlos
Negrete. Pt al, L-7ross-Mefendants
OCSC Case No. 652709
Steohen Julian v. Times Mirror o.. =T al.,
OCSC Case No. 67 73 41
Dear Suzanne:
This letter is to thank you for your help in coordinating the
settlement of the above -referenced matter. As you are aware, the
settlement was very difficult due to the number of parties
MAR 0 3 1994
0
City of San Juan Capistrano
Attn.: Suzanne Ramsey
March 2, 1994
Page 2
0
involved and your assistance was invaluable in accomplishing a
final resolution of this matter.
Enclosed please find the original City Settlement Aareement and a
Copy of the Addendum thereto. Again, thank you for ;our
cooperation and courtesy.
Very truly/ yours,
wlLli vv/ j
ANN K. JOHNSTON, for
BERGER, KAHN, SHAFTC:., MOSS,
FIGLER, SIMON & GLADSTC-NE
A Professional Corperation
AKJ:kmh
Enclosures