HomeMy WebLinkAboutMINUTES - 10101995 - CS cs
SUPPLEMENTAL CALENDAR OF CLOSED SESSION ITEMS
FOR THE BOARD OF SUPERVISORS
CONTRA COSTA COUNTY
AND FOR
SPECIAL DISTRICTS,AGENCIES,AND
AUTHORITIES GOVERNED BY THE BOARD .
BOARD CHAMBERS AND ROOM 105,ADMINISTRATION BUILDING,
TUESDAY',OCTOBER 10, 1995 8:30 A.M.AND THEREAFTER
DURING THIS REGULAR OCTOBER 10, 1995 MEETING
A. EXISTING LITIGATION-CONFERENCE WITH LEGAL COUNSEL (LITIGATION HAS BEEN
FORMALLY INITIATED,GOV,CODE.§54956.9(A).).CASES:
1. Dorothy Fellinger v.County.of Contra Costa,
WCAB No.WCK 0004401
2. Anchor Glass v.County of Contra Costa,
Sup.Ct. No.C94-00042
3. Acme Fill Corp.v.Althin CD Medical, Inc.
Acme Fill Com.v.County of Contra Costa
4.. Margarita Carreon v.County of Contra Costa,
Sup,Ct. No.95-03331
5. Waste Management v.County of Contra Costa
B. CONFERENCE WITH LABOR NEGOTIATORS
1. Agengy Negotiators:Leslie Knight, Richard Heyne,and Keith Fleming(IEDA).
Employee Organizations:Contra Costa County Employees'Assoc.,Local No. 1;AFSCME
Locals 512 and 2700;.Calif.Nurses Assoc.(CNA);SEW and Social Services Union Local
#535;C.C.C.Appraiser's Assn.;District Attorneys Inspectors Assoc.;Deputy Sheriffs Assn.
(DSA); United Prof.Firefighters,Local 1230;Contra Costa Physicians Union;Western
Council of Engineers;and Teamsters Local 314.
2. Agency Negotiator.Phil Batchelor
Unrepresented Employees:.Social Service, Health Services,and Growth Management and
Economic Development Agency Directors,and County Counsel.
3. Agee Negotiator Victor Westman
Unrepresented Employee:County Administrator
4. Agency Negotiators: Leslie Knight and Lee Finney(IEDA)
Employee Organizations:Contra Costa County Employees'Assoc., Local No. 1;AFSCME
Loca12700.
VJWgmm
10.10-95MMgmcs -
10.5-95 -
�s
COUNTY COUNSEL ' S OFFICE RECEIVED
CONTRA COSTA COUNTY
MARTINEZ, CALIFORNIA
WC 2 01995
Date: December 20 1995
LD OF SU+'Ea'.
CONTRA COST�s Ce.:
To: Jeanne Maglio, Chief Clerk of the Board of Supervisors
From: Victor J. Westman, County Counsel
By: Silvano B. Marchesi, Ass't County Counsel JDD
B
Re: Waste Management, Inc., et al. v. Contra Costa County, et al.
In closed session on December 19, 1995, the Board of Supervisors voted to approve the
enclosed settlement agreement in connection with the above lawsuit. The vote was as follows:
Ayes: Bishop, Rogers, DeSaulnier
Noes: None
Abstain: None
Absent: Smith, Torlakson
Chair Bishop signed the agreement later in the day. We have received a faxed copy
of a signature on behalf of Waste Management. Upon receipt of a hard copy, we will forward
it to you for your file.
Please sign each of the two enclosed agreements on behalf of Phil Batchelor. Also,
please place copies of the agreement and this memo in the press box. Finally, please return
one of the signed agreements to this office for transmittal to Waste Management.
Thank you for your assistance.
Enclosures
SETTLEMENT AGREEMENT,
MUTUAL RELEASE AND COVENANT
NOT TO SUE
This Settlement Agreement, Mutual Release and Covenant Not
to Sue ("Agreement") is entered into by and between Waste
Management, Inc. and Waste Management of California, Inc.
(collectively "Waste Management") , on the one hand, and the
County of Contra Costa, a political subdivision of the State of
California, and Kenneth J. Corcoran as auditor-controller of the
County (collectively "County") , on the other hand. Waste
Management and County are sometimes referred to in this Agreement
as the "Parties."
RECITALS
A. There is now pending in the Superior Court of the State
of California, in and for the County of Contra Costa, an action
entitled Waste Management, Inc. , and Waste Management of
California, Inc. v. County of Contra Costa, et a1. , No. C 95-
00246 (the "Action",) .
B. The Parties desire to compromise the Action completely
between themselves without any admission of liability and to
avoid the expense of further litigation.
AGREEMENT
1 . This Agreement shall be effective on the date last
executed by a Party.
2 . County shall pay to Waste Management, by check or
warrant payable to Waste Management, Inc. and delivered to its
counsel, the sum of Four Hundred Thousand Dollars ($400, 000) .
Payment shall be delivered on or before December 28, 1995, or
five working days after County receives proof of Waste
Management' s execution of this Agreement, whichever is later. If
County fails to make timely payment, County shall pay to Waste
Management interest at the rate of 7% per annum, compounded
annually, from December 28, 1995 until the date of payment.
3. Waste Management shall dismiss the Action as to all
defendants with prejudice within five days of payment by the
County pursuant to Section 2 . Waste Management hereby
authorizes and directs its counsel to prepare, execute and file
the dismissal with prejudice upon delivery of payment.
4 . Except for the ability to enforce this Agreement, each
Party releases and forever discharges the other of and from and
waives any and all claims, demands, controversies, actions,
causes of action, obligations, damages and liabilities of any
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 2 of 5
nature whatsoever, whether at law or in equity that it ever had,
now has, or that it may hereafter have against the other and that
arise out of the subject matter of the Action. For purposes of
this Agreement, "subject matter of the Action" means any and all
matters relating to the Marsh Canyon Landfill, including the
application for, processing, approval, administration and
withdrawal of Land Use Permit No. 2020-89, including its
conditions of approval and fees paid pursuant thereto, and
related actions, such as the Marsh Canyon Landfill Franchise
Agreement and the proposed March Canyon Landfill Development
Agreement. However, this release and waiver does not include
claims for nonpayment of taxes or other valid governmental
assessments.
5. The waivers and releases in this Agreement include
waivers and releases of any claims for costs, expenses and
attorneys' fees, taxable and otherwise, incurred in or arising
out of the prosecution or defense of the Action. The claims
waived and released in this Agreement include claims that arise
out of the subject matter of the Action against employees,
agents, , officers, directors and partners of each Party in their
individual capacities, as well as claims against the Parties .
6. Each Party understands that it may have sustained
damages that may not have manifested themselves and are -presently
unknown, or that may arise out of or relate to the subject matter
of the Action. The waivers and releases in this Agreement
include waivers and releases of any claims for those damages.
The waivers and releases in this Agreement also include waivers
and releases of any other claims for unknown or unanticipated
injuries, losses, or damages arising out of or relating to the
subject matter of the Action.
7 . Each Party waives, with respect to the subject matter of
the Action, all rights or benefits that it has or may have under
Section 1542 of the Civil Code of the State of California to the
extent it would otherwise apply. Section 1542 reads as follows:
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.
8 . Each Party agrees- that it will not commence, maintain or
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 3 of 5
continue the prosecution by any other person or entity of any
claim against the other, or any present or former employee of the
other, relating to any matter waived or released in this
Agreement.
9. Each Party declares that prior to the execution of this
Agreement, it or its duly authorized representatives have
apprised themselves of sufficient relevant data, either through
experts or other sources of their own selection, in order that
each Party might intelligently exercise its judgment in deciding
whether to execute, and in deciding on the contents of, this
Agreement. Each Party assumes the risk that facts, other than
those facts that may be represented or warranted to be true in
this Agreement or are now believed by it to be true,' may later be
found to be other than or different from the facts now believed
by it to be true. Each Party declares that its decision to
execute this Agreement is not influenced by any representation
not contained in this Agreement. Each Party has had this
Agreement explained to it by its attorney, and each Party
declares that it has executed this Agreement freely and
voluntarily, with full knowledge of its significance and
contents .
10. Neither the transfer of any consideration, the doing of
any of the acts referred to in this Agreement, nor anything else
contained in this Agreement shall be construed to be an admission
on the part of any of the Parties of any liability for any claims
asserted in the Action by any of the other Parties. The Parties
deny all such claims.
11 . Each Party represents and warrants that it has the sole
right and. exclusive authority to execute this Agreement, and that
it has not sold,, assigned, transferred, conveyed, or otherwise
disposed of any claim or demand against the other relating to any
matter covered by this Agreement. Each Party represents that it
is duly authorized to enter into this Agreement, and each person
signing on behalf of an entity represents that he or she is duly
authorized to sign on behalf of that entity.
12 . Each Party agrees that if it breaches any provision of
this Agreement, it will indemnify and hold harmless each of the
other Parties from and against any and all claims, demands,
causes of action, obligations, damages and liabilities, including
court or arbitration costs and attorneys` fees, arising from or
in connection with that breach.
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 4 of 5
13. This Agreement shall be construed in accordance with,
and governed by, the laws of the State of California applicable
to contracts between California residents made and to be
performed in California.
14 . The Parties mutually acknowledge that they and their
attorneys have participated in the preparation and negotiation of
this Agreement. In cases of uncertainty this Agreement shall be
construed without regard to which of the Parties caused the
uncertainty to exist.
15. This Agreement may be executed .in multiple
counterparts, each of which shall be deemed an original, and
counterpart signature pages may be assembled to form a single
original document. The Parties agree that signatures received
via facsimile transmission shall in all respects be deemed to be
original signatures.
16. Each Party to this Agreement shall at its own expense
perform all acts and execute all documents and instruments that
may be _necessary or convenient to carry out its obligations under
this Agreement.
17 . This Agreement sets forth the entire understanding of
the Parties relating to the transactions it contemplates and
supersedes all prior understandings relating to them, whether
written or oral . There are no obligations, commitments,
representations or warranties relating to them except those
expressly set forth in this Agreement.
18 . Nothing in this Agreement, whether express or implied,
is intended to do any of the following:
(a) confer any benefits, rights or remedies under or
by reason of this Agreement on any persons other than the
express Parties to it, their respective permitted successors
and assigns;
(b) relieve or discharge the obligation or liability
of any person not an express Party to this Agreement except
as provided in section 5 above; or
(c) give any person not an express Party to this
Agreement any right of subrogation or action against any
Party to this Agreement.
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 5 of 5
19. No amendment of, supplement to or waiver of any
obligations under or provisions of this Agreement will be
enforceable or admissible unless set forth in a writing signed by
all Parties . Any waiver granted shall apply solely to the
specific instance expressly stated.
20. If legal action or other proceeding is commenced as a
result of a dispute which arises under or relates to any
provision of this Agreement, all Parties shall pay their own
attorneys' fees and expenses incurred in preparation for and
conduct of that action or proceeding, appeal of judgment, and
enforcement and collection of judgment. These fees and expenses
include but are not limited to those spent on collection of the
resulting judgment. All these fees and expenses shall be made
part of any judgment entered as a result of any dispute arising
under or relating to any provision of this Agreement.
.21 . As used in this Agreement, the terms "it", "he", "his"
or "him" refer to each Party regardless of whether the Party is a
male, female, corporation, partnership or other entity.
County of Contr Costa
DATED: SFr, 1 ^ 195
By:
Attest: Phil Batch ' ior,
Clerk of the Board and
County Administrator
Approved as to Form:
Victor J. Westman, County Counsel
By:
Waste Management, Inc. and
Waste Management of California, Inc.
DATED: By:
Approved as to Form:
McCUTCHEN, DOYLE, BROWN & ENERSON
26a:\stt11215.95f By
December 15, 1995
t.
RECEIVED
COUNW COUNSEL'S OFFICE DEC 2119%
CONTRA COSTA COUNTY
MARTINEZ, CALIFORNIA
CLERK BOARD OF SUPERVISORS
CONTRA COSTA CO.
Date: December 21, 1995
To: Jeanne Maglio, Chief Clerk of the Board of Supervisors
From: Victor J. Westman, County Counsel
By: Lillian T. Fujii, Deputy County unsel
Re: Waste Management, Inc., et al. v. Contra Costa County, et al.
Concerning the settlement agreement approved by the Board in closed session
on December 19, 1995, enclosed for your file is a hard copy of the agreement signed by
Waste Management.
The hard copy of the agreement signed by the Board Chair that you returned
to us has been transmitted to Waste Management via its attorneys, McCutchen, Doyle,
Brown & Enersen.
Encl.
SETTLEMENT AGREEMENT,
MUTUAL RELEASE AND COVENANT .
NOT TO SUE
This Settlement Agreement, Mutual Release and Covenant Not
to Sue ("Agreement") is entered into by and between Waste
Management, Inc. and Waste Management of California, Inc.
(collectively "Waste Management") , on the one hand, and the
County of Contra Costa, a political subdivision of the State of
California, and Kenneth J. Corcoran as auditor-controller of the
County (collectively "County") , on the other hand. Waste
Management and County are sometimes referred to in this Agreement
as the "Parties . "
RECITALS
A. There is now pending in the Superior Court of the State
of California, in and for the County of Contra Costa, an action
entitled Waste Management, Inc. , and Waste Management of
California, Inc. v. County of Contra Costa, et al . , No. C 95-
00246 (the "Action") .
B. The Parties desire to compromise the Action completely
between themselves without any admission of liability and to
avoid the expense of further litigation.
AGREEMENT
1 . This Agreement shall be effective on the date last
executed by a Party.
2 . County shall pay to Waste Management, by check or
warrant payable to Waste Management, Inc. and delivered to its
counsel, the sum of Four Hundred Thousand Dollars ($400, 000) .
Payment shall be delivered on or before December 28, 1995, or
five working days after County receives proof of Waste
Management' s execution of this Agreement, whichever is later. If
County fails to make timely payment, County shall pay to Waste
Management interest at the rate of 7% per annum, compounded
annually, from December 28, 1995 until the date of payment.
3 . Waste Management shall dismiss the Action as to all
defendants with prejudice within five days of payment by the
County pursuant to Section 2 . Waste Management hereby
. authorizes and directs its counsel to prepare, execute and file
the dismissal with prejudice upon delivery of payment.
4 . Except for the ability to enforce this Agreement, each
Party releases and forever discharges the other of and from and
waives any and all claims, demands, controversies, actions,
causes of action, obligations, damages and liabilities of any
December 15, 1995
ORIGINAL
Settlement Agreement between
Waste Management and County
Page 2 of 5
nature whatsoever, whether at law or in equity that it ever had,
now has, or that it may hereafter have against the other and that
arise out of the subject matter of the Action. For purposes of
this Agreement, "subject matter of the Action" means any and all
matters relating to the Marsh Canyon Landfill, including the
application for, processing, approval, administration and
withdrawal of Land Use Permit No. 2020-89, including its
conditions of approval and fees paid pursuant thereto, and
related actions, such as the Marsh Canyon Landfill Franchise
Agreement and the proposed March Canyon Landfill Development
Agreement . However, this release and waiver does not include
claims for nonpayment of taxes or other valid governmental
assessments .
5. The waivers and releases in this Agreement include
waivers and releases of any claims for costs, expenses and
attorneys` fees, taxable and otherwise, incurred in or arising
out of the prosecution or defense of the Action. The claims
waived and released in this Agreement include claims that arise
out of the subject matter of the Action against employees,
agents, officers, directors and partners of each Party in their
individual capacities, as. well as claims against the Parties .
6. Each Party understands that it may have sustained
damages that may not have manifested themselves and are presently
unknown, or that may arise out of or relate to the subject matter
of the Action. The waivers and releases in this Agreement
include waivers and releases of any claims for those damages.
The waivers and releases in this Agreement also include waivers
and releases of any other claims for unknown or unanticipated
injuries, losses, or damages arising out of or relating to the
subject matter of the Action.
7 . Each Party waives, with respect to the subject matter of
the Action, all rights or benefits that it has or may have under
Section 1542 of the Civil Code of the State of California to the
extent it would otherwise apply. Section 1542 reads as follows:
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.
B . Each Party agrees that it will not commence, maintain or
December 15, 1995
c.
Settlement Agreement between
Waste Management and County
Page 3 of 5
continue the prosecution by any other person or entity of any
claim against the other, or any present or former employee of the
other, relating to any matter waived or released in this
Agreement.
9. Each Party declares that prior to the execution of this
Agreement, it or its duly authorized representatives have
apprised themselves of sufficient relevant data, either through
experts or other sources of their own selection, in order that
each Party might intelligently exercise its judgment in deciding
whether to execute, and in deciding on the contents of, this
Agreement. Each Party assumes the risk that facts, other than
those facts that may be represented or warranted to be true in
this Agreement or are now believed by it to be true, may later be
found to be other than or different from the facts now believed
by it to be true. Each Party declares that its decision to
execute this Agreement is not influenced by any representation
not contained in this Agreement. Each Party has had this
Agreement, explained to it by its attorney, and each Party
declares that it has executed this Agreement freely and
voluntarily, with full knowledge of its significance and
contents .
10. Neither the transfer of any consideration, the doing of
any of the acts referred to in this Agreement, nor anything else
contained in this Agreement shall be construed to be an admission
on the part of any of the Parties of any liability for any claims
asserted in the Action by any of the other Parties . The Parties
deny all such claims .
11 . Each Party represents and warrants that it has the sole
right and exclusive authority to execute this Agreement, and that
it has not sold, assigned, transferred, conveyed, or otherwise
disposed of any claim or demand against the other relating to any
matter covered by this Agreement. Each Party represents that it
is duly authorized to enter into this Agreement, and each person
signing on behalf of an entity represents that he or she is duly
authorized to sign on behalf of that entity.
12 . Each Party agrees that if it breaches any provision of
this Agreement, it will indemnify and hold harmless each of the
other Parties from and against any and all claims, demands,
causes of action, obligations, damages and liabilities, including
court or arbitration costs and attorneys' fees, ,arising from or
in connection with that breach.
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 4 of 5
13 . This Agreement shall be construed in accordance with,
and governed by, the laws of the State of California applicable
to contracts between California residents made and to be
performed in California.
14 . The Parties mutually acknowledge that they and their
attorneys have participated in the preparation and negotiation of
this Agreement. In cases of uncertainty this Agreement shall be
construed without regard to which of the Parties caused the
uncertainty to exist.
15. This Agreement may be executed in multiple
counterparts, each of which shall be deemed an original, and
counterpart signature pages may be assembled to form a single
original document. The Parties agree that signatures received
via facsimile transmi-ssion shall in all respects be deemed to be
original signatures .
16. ' Each Party to this Agreement shall at its own expense
perform all acts and execute all documents and instruments that
may be necessary or convenient to carry out its obligations under
this Agreement.
17 . This Agreement sets forth the entire understanding of
the Parties relating to the transactions it contemplates, and
supersedes all prior understandings relating to them, whether
written or oral . There are no obligations, commitments,
representations or warranties relating to them except those
expressly set forth in this Agreement.
18 . Nothing in this Agreement, whether express or implied,
is intended to downy of the following:
(a) confer any benefits, rights or remedies under or
by reason of this Agreement on any persons other than the
express Parties to it, their respective permitted successors
and assigns;
(b) relieve or discharge the obligation or liability
of any person not an express Party to this Agreement except
as provided in section 5 above; or ,
(c) give any person not an express Party to this
.Agreement any right of subrogation or action against any
Party to this Agreement.
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 5 of 5
19. No amendment of, supplement to or waiver of any
obligations under or provisions of this Agreement will be
enforceable or admissible unless set. forth in a writing signed by
all Parties . Any waiver granted shall apply solely to the
specific instance expressly stated.
20 . If legal action or other proceeding is commenced as a
result of a dispute which arises under or relates to any
provision of this Agreement, all Parties shall pay their own
attorneys ' fees and expenses incurred in preparation for and
conduct of that action or proceeding, appeal of judgment, and
enforcement and collection of judgment. These fees and expenses
include but are not limited to those spent on collection of the
resulting judgment. All these fees and expenses shall be made
part of any judgment entered as a result of any dispute arising
under or relating to any provision of this Agreement.
21 . As used in this Agreement, the terms "it", "he", "his"
or "him" refer to each Party regardless of whether the Party is a.
male, female, corporation, partnership or other entity.
County of Contra Costa
DATED: By:
Attest: Phil Batchelor,
Clerk of the Board and
County Administrator
By:
Approved as to Form:
Victor J. Westman, County Counsel
By:
Waste Management, Inc. and
Waste Management of California, Inc.
DATED: December 19, 1995 By
P esi ent
App ved as to Form:
McCUTCHEN, DOYLE, BROWN & ENERSON
26a:\stt11215.95f B y: �
December 15, 1995
COUNTY COUNSEL' S OFFICE
CONTRA COSTA COUNTY
MARTINEZ, CALIFORNIA
Date: December 20, 1995
To: Jeanne Maglio, Chief Clerk of the Board of Supervisors
From: --Victor J. Westman, County Counsel
By: Silvano B. Marchesi, Ass't County Counsel
Re: Waste Management, Inc., et al. v. Contra Costa County, et al.
In closed session on December 19, 1995, the Board of Supervisors voted to approve the
enclosed settlement agreement in connection with the above lawsuit. The vote was as follows:
Ayes: Bishop, Rogers, DeSaulnier
Noes: None
Abstain: None
Absent: Smith, Torlakson
Chair Bishop signed the agreement later in the day. We have received a faxed copy
of a signature on behalf of Waste Management. Upon receipt of a hard copy, we will forward
it to you for your file.,
Please sign each of the two enclosed agreements on behalf of Phil Batchelor. Also
please place copies of the agreement and this memo in the press box. Finally, please return
one of the signed agreements to this office for transmittal to Waste Management.
Thank you for your assistance.
Enclosures
COUNTY COUNSEL' S OFFICE RECEIVED
CONTRA COSTA COUNTY
MARTINEZ, CALIFORNIA q
[.L2 0 1995
Date: December 20, 1995CLE'�C OF SUPER
CONTRA COSTA C(:
To: Jeanne Maglio, Chief Clerk of the Board of Supervisors
From: Victor J. Westman, County Counsel
By: Silvano B. Marchesi, Ass't County Counsel'A V
Re: Waste Management, Inc., et al. v. Contra Costa County, et al.
In closed session on December 19, 1995, the Board of Supervisors voted to approve the
enclosed settlement agreement in connection with the above lawsuit. The vote was as follows:
Ayes: Bishop, Rogers, DeSaulnier
Noes: None
Abstain: None
Absent: Smith, Torlakson
Chair Bishop signed the agreement later in the day. We have received a faxed copy
of a signature on behalf of Waste Management. Upon receipt of a hard copy, we will forward
it to you for your file.
Please sign each of the two enclosed agreements on behalf of Phil Batchelor. Also,
please place copies of the agreement and this memo in the press box. Finally, please return
one of the signed agreements to this office for transmittal to Waste Management.
Thank you for your assistance.
Enclosures
SETTLEMENT AGREEMENT,
MUTUAL RELEASE AND COVENANT
NOT TO SUE
This Settlement Agreement, Mutual Release and Covenant Not
to Sue ("Agreement") is entered into by and between Waste
Management, Inc. and Waste Management of California, Inc.
(collectively "Waste Management") , on the one hand, and the
County of Contra Costa, a political subdivision of the State of
California, and Kenneth J. Corcoran as auditor-controller of the
County (collectively "County") , on the other hand. Waste
Management and County are sometimes referred to in this Agreement
as the "Parties."
RECITALS
A. There is now pending in the Superior Court of the State
of California, in and for the County of Contra Costa, an action
entitled Waste Management, Inc. , and Waste Management of
California, Inc. v. County of Contra Costa, et a1. , No. C 95-
00246 (the "Action") .
B. The Parties desire to compromise the Action completely
between themselves without any admission of liability and to
avoid the expense of further litigation.
AGREEMENT
1 . This Agreement shall be effective on the date last
executed by a Party.
2. County shall pay to Waste Management, by check or
warrant payable to Waste Management, Inc. and delivered to its
counsel, the sum of Four Hundred Thousand Dollars ($400, 000) .
Payment shall be delivered on or before December 28, 1995, or
five working days after County receives proof of Waste
Management's execution of this Agreement, whichever is later. If
County fails to make timely payment, County shall pay to Waste
Management interest at the rate of 7% per annum, compounded
annually, from December 28, 1995 until the date of payment.
3. Waste Management shall dismiss the Action as to all
defendants with prejudice within five days of payment by the
County pursuant to Section 2. Waste Management hereby
authorizes and directs its counsel to prepare, execute and file
the dismissal with prejudice upon delivery of payment.
•
4 . Except for the ability to enforce this Agreement, each
Party releases and forever discharges the other of and from and
waives any and all claims, demands, controversies, actions,
causes of action, obligations, damages and liabilities of any
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 2 of 5
nature whatsoever, whether at law or in equity that it ever had,
now has, or that it may hereafter have against the other and that
arise out of the subject matter of the Action. For purposes of
this Agreement, "subject matter of the Action" means any and all
matters relating to the Marsh Canyon Landfill, including the
application for, processing, approval, administration and
withdrawal of Land Use Permit No. 2020-89, including its
conditions of approval and fees paid pursuant thereto, and
related actions, such as the Marsh Canyon Landfill Franchise
Agreement and the proposed March Canyon Landfill Development
Agreement. However, this release and waiver does not include
claims for nonpayment of taxes or other valid governmental
assessments.
5. The waivers and releases in this Agreement include
waivers and releases of any claims for costs, expenses and
attorneys' fees, taxable and otherwise, incurred in or arising
out of the prosecution or defense of the Action. The claims
waived and released in this Agreement include claims that arise
out of the subject matter of the Action against employees,
agents, •. officers, directors and partners of each Party in their
individual capacities, as well as claims against the Parties.
6. Each Party understands that it may have sustained
damages that may not have manifested themselves and are -presently
unknown, or that may arise out of or relate to the subject matter
of the Action. The waivers and releases in this Agreement
include waivers and releases of any claims for those damages.
The waivers and releases in this Agreement also include waivers
and releases of any other claims for unknown or unanticipated
injuries, losses, or damages arising out of or relating to the
subject matter of the Action.
7 . Each Party waives, with respect to the subject matter of
the Action, all rights or benefits that it has or may have under
Section 1542 of the Civil Code of the State of California to the
extent it would otherwise apply. Section 1542 reads as follows:
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 hist
must have materially affected his settlement
with the debtor.
8. Each Party agrees that it will not commence, maintain or
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 3 of 5
continue the prosecution by any other person or entity of any
claim against the other, or any present or former employee of the
other, relating to any matter waived or released in this
Agreement.
9. Each Party declares that prior to the execution of this
Agreement, it or its duly authorized representatives have
apprised themselves of sufficient relevant data, either through
experts or other sources of their own selection, in order that
each Party might intelligently exercise its judgment in deciding
whether to execute, and in deciding on the contents of, this
Agreement. Each Party assumes the risk that facts, other than
those facts that may be represented or warranted to be true in
this Agreement or are now believed by it to be true, may later be
found to be other than or different from the facts now believed
by it to be true. Each Party declares that its decision to
execute this Agreement is not influenced by any representation
not contained in this Agreement. Each Party has had this
Agreement explained to it by its attorney, and each Party
declares that it has executed this Agreement freely and
voluntarily, with full knowledge of its significance and
contents .
10. Neither the transfer of any consideration, the doing of
any of the acts referred to in this Agreement, nor anything else
contained in this Agreement shall be construed to be an admission
on the part of any of the Parties of any liability for any claims
asserted in the Action by any of the other Parties. The Parties
deny all such claims .
11 . Each Party represents and warrants that it has the sole
right and exclusive authority to execute this Agreement, and that
it has not sold, assigned, transferred, conveyed, or otherwise
disposed of any claim or demand against the other relating to any
matter covered by this Agreement. Each Party represents that it
is duly authorized to enter into this Agreement, and each person
signing on behalf of an entity represents that he or she is duly
authorized to sign on behalf of that entity.
12. Each Party agrees that if it breaches any provision of
this Agreement, it will indemnify and hold harmless each of the
other Parties from and against any and all claims, deipands,
causes of action, obligations, damages and liabilities, including
court or arbitration costs and attorneys' fees, arising from or
in connection with that breach.
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 4 of 5
13. This Agreement shall be construed in accordance with,
and governed by, the laws of the State of California applicable
to contracts between California residents made and to be
performed in California.
14 . The Parties mutually acknowledge that they and their
attorneys have participated in the preparation and negotiation of
this Agreement. In cases of uncertainty this Agreement shall be
construed without regard to which of the Parties caused the
uncertainty to exist.
15. This Agreement may be executed in multiple
counterparts, each of which shall be deemed an original, and
counterpart signature pages may be assembled to form a single
original document. The Parties agree that signatures received
via facsimile transmission shall in all respects be deemed to be
original signatures.
16. Each Party to this Agreement shall at its own expense
perform all acts and execute all documents and instruments that
may be necessary or convenient to carry out its obligations under
this Agreement.
17 . This Agreement sets forth the entire understanding of
the Parties relating to the transactions it contemplates> and
supersedes all prior understandings relating to them, whether
written or oral. There are no obligations, commitments,
representations or warranties relating to them except those
expressly set forth in this Agreement.
18 . Nothing in this Agreement, whether express or implied,
is intended to do any of the following:
(a) confer any benefits, rights or remedies under or
by reason of this Agreement on any persons other than the
express Parties to it, their respective permitted successors
and assigns;
(b) relieve or discharge the obligation or liability
of any person not an express Party to this Agreement except
as provided in section 5 above; or
(c) give any person not an express Party to this
Agreement any right of subrogation or action against any
Party to this Agreement.
December 15, 1995
Settlement Agreement between
Waste Management and County
Page 5 of 5
19. No amendment of, supplement to or waiver of any
obligations under or provisions of this Agreement will be
enforceable or admissible unless set forth in a writing signed by
all Parties. Any waiver granted shall apply solely to the
specific instance expressly stated.
20. If legal action or other proceeding is commenced as a
result of a dispute which arises under or relates to any
provision of this Agreement, all Parties shall pay their own
attorneys' fees and expenses incurred in preparation for and
conduct of that action or proceeding, appeal of judgment, and
enforcement and collection of judgment. These fees and expenses
include but are not limited to those spent on collection of the
resulting judgment. All these fees and expenses shall be made
part of any judgment entered as a result of any dispute arising
under or relating to any provision of this Agreement.
21 . As used in this Agreement, the terms "it", "he", "his"
or "him" refer to each Party regardless of whether the Party is a
male, female, corporation, partnership or other entity.
County of Contr Costa
--"DATED: nFr, 1 � X995 By:
�- �/
Attest: Phil Batch4g. or,
Clerk of the Board and
County Administrator
By:�
Approved as to Form:
Victor J. Westman, County Counsel
By:
Waste Management, Inc. and
Waste Management of California, Inc.
DATED: By:
Approved as to Form:
McCUTCHEN, DOYLE, BROWN & ENERSON
26a:\stt11215.95f By
December 15, 1995