Loading...
HomeMy WebLinkAboutPacific Mobile Home Park, LLC - Legacy 42680 Holdings, LLC - Foothill to Summit Properties, LLC - Sizable Properties, LLC - 2013-02-08 SETTLEMENT AGREEMENT AND ATUTUAL RELEASE This Settlement Agreement and Mutual Release (the"Agreement')is made and entered flit) by anti. beiweeii %lie i l i. i 2irAQH oht; "City"? atidl rAi:IPIC MOBILE HOME PARK. LLC ("Pacific LLC'7. LEGACY 42680 HOLDINGS. LLC, -`Legacy"), FOOTHILL TO SUMMIT PROPERTIES, LLC, ff oothilF): and SIZABLE 1 n 3i'Eltii]r`:5,LLC- iZfiriie"}. 'ihe City and Pacific sire individually reierred'lo as a"Parry'' and collectively as"the Parties." This Agreement is entered into nn February M, .2013 pursuant to fue foilwWing terms and cons iiians: RECFTTALS A. Pacific ividuiie H otne Park i.ocatud ai 'W H uniingion Sheer= Huntington Beach, California 92648(the"Park"). The Park is currently a for-rent mobile home park with a total of 252 units located at 80 Huntington Street (souiheast comer of Huntington Street and Atlanta Avenue,). The Park was previously owned by Pacific 11 C. in Decenn bur 2ii12,Pacific LLC:s rransfi=edr its interest in the Park to Legacy. Foothill and Sizable. Legacy, Foothill and Sizable are collectively referred to in this Agreement as `Pacific ' Ii_ 'Hie City Idlaims tut edstmelit for a 6i5 loot wide pubuc mgm-of-wav in Huniingtlin :Street.which lies between Atlanta Avenue and Pacific View tivenue.adiacent to racwc iviulii'le nome Pant `iitiiliiis din R16-t of W av`!)_ The Ciiy retarded an easement deed, which was accepted by the Huntington Beach City Council __. ._punmanni 1o_krs6lutiun are copies of the deed and City Council Resolution No. 1125,respectively. C. lluciflc LLC has inisia'ded a wooden enct:within the HundAiaon Right of"Way. Behind the fence are mobile homes and related structures. D. On December 7, 2010. Pacific.LLC submitted to the City Tentative Tract Man No. f1391 and Coasud Development i etaiii No. 10-011 (coilectivefy,the`'iract Map"j to convert the Park from a rental to a resident-owned mobile home park pursuant to Vovernment Code Section 6642i.5. the City Council denied the Tract Map on June b.2011 E. On August 5.2011,Pacific LLC shed the City to clialleage the denial of the Tract Map by filing the suit entitled _Pacific Mobile Home Park LLC v Ciiv of Ruminglun,Beach, Orange County Superior Court Case No. 30-2011-00497684, Court of Appeal Case No.G047060(the"Action'). F. On February 6, 201Z, the City filed its First Amended Cross-Complaint in the Action against Pacific,the 23 mobile home owners abutting the Huntington Right of Way.and the California Department of Housing and Community Development G. The Cross-Complaint in the Action sought to remove the encroachments in the Huntington Right of Wav and in the three-foot setback area. Pacific LLC 1 1i 3iAAM062 challenged the Cross-Complaint by way of an anti-SLAPP motion filed pursuant to node oC Civii rroct;La-e Sectiuri 425.16. the Cuurt 6eaied-that motion in-ice .Action on April 20,2012. Pacific appealed the denial of the anti-SLAPP motion in the Action,resulting in Court of Appeal Case No.G047060. On August 30,.2W2,the Coun entered a judgment and issued a Peremptory WTIt in the Action which ordered the City to set aside its earlier denial of the Tract Map and reconsider Pacifies tract Map without Iegard to Whether The subdivided. units encroached on the Ciiv's right of-way. 1. On November 19. 2012. the Huntington Beach City Council approved Pacifies Tract flap. riowever. at its December a, 2)i2 weer mg: The .:it_y Council determined to reconsider the Tract Map at a public hearing on January 22.2013_ 3 On December 1 Q,2012,Pacific applied for, and the Court granted an Order inthe _ _ t S t 1°iL6on ilte iitug ihe; �'ie�tdber .7,, 1012 1wmufUeration aulon void, `dull iur.uer barring the City from.reconsidering the Tract Map. K. On December 17,2012,the City Council:affirmed its vote to reconsider the Tract `idjap m IhV Iulart. The cu"1611 luck no au iuii to conduct a public 4it-ai ig !U reconsiderthe subdivision. L_ On January 10.2013,the Court set an Order to Show Cause heating in the Action to ueiermine it December 1 , 2012 vote of tine City Council violated the _._._..-I3ecern-liec3r 20I2Cotut Clyder: . M. On January 14. 2013 and January 22. 20I3. the City Council determined to abandon-reconsideration of the Tract Map. The effect ofthe City C ouncil's action is to set aside and reverse the Council's earlier actions to reconsider the approval of the Tract Map, and instead affirm and reinstate the November 19„ 2012 approval of the Tract Map. N. Pacific represents that prior to the City's actions of December 3 and 17,2012 to reconsider approval of the Tract Map,Pacific bad entered into an agreement to sell the Park to Cocke, Finkelstein Inc. and the Carlyle Group {the "Sale'. Pacific further represents that as subsequent to the City's actions to reconsider approval of the Tract Map,including the City's actions of December 3 and 17, 2DI2,the Sale was cancelled,resulting in damages to Pacific. O. The Parties have vigorously litigated the Action. The Parties now wish to avoid the expense, delay and uncertainty of litigation and to settle the disputes among them. P. By entering into this Agreement, City confirms .its prior approval of the Tract Map. M 77-;cnar43nF2 AGREFAIENT For and in consideration of the commitments made herein, City and Pacific agree as 1. In making this Agreement,the Parties do not admit the sufficiency of any claims, allegations;assertions, contentions ur positions of any oilier Parcv, or the sufficiency of any defenses to any such claims, allegations_. assertions_ contentions or positions. including the Rechals to finis Agreement ruriner, in mating finis Agreements the Parties agree that the covenant and release comprising this Agreement are not intended to be admissions of liability. negligence,willful conduct, preach of contract or fault of any kind whatsoever, by any seWing party. The Parties desire to resolve their disputes in an amicable manner with the desire to zorever settle as between inem any and ail claims,any and all disputes regarding file i'ract lviap, Huntineton Right of Wav and Sale.and all matters relating thereto. 2. Pacific and City agree that in the event the approval of the Tract Map is .challenged or otherwise does not:become hrial,Pacific may cancel tUis Agreement. 3. YbLe parties apace,ti;ai: a. City shall dismiss its Cross-Complaint in the Action as to all Cross- Dofenclams whhout prejudice, provided That as to the Cross-Deiendants oilier Than Pacific, the City will only be required to dismiss the Cross-Complaint as to Cross- . .. consented to dismissal without prejudice. b. On full execution of this Agreement, Pacific shall dismiss its appeal pending regarding the denial of Pacifies SLAPP motion:and C. .Any pending motions in the Action shall he taken off calendar and the Parties shal} consent to the pending order to show cause re: contempt being dismissed, and d. This Agreement shall not be effective until the hearing on the order to bow C&LIse it'. CUIYLebT I is d6mis-s�s PIOV E;d however, 'lkaa tie hivalldatien of hits Agreement shall not affect or impact the Citv's approval of the Tract Map. 4. Except for the obligations of the Parties as set forth in this Agreement. City and Pacific for themselves, their sureties and their affiliates, and their respective predecessors, successors,insurers and owners,hereby Puny it-lease and discharge each ofner iogetherwith their respective predecessors, successors, divisions. affiliates, units, parents. subsidiaries, shareholders, officers, directors, attornevss employees including former employees, agents, council members,members, contractors,insurers,sureties,subcontractors and representatives of all kinds, any and all existing claims.actions,causes of action,agreements. demands contracts, covenants, obligations, defies, dames, aftomey's ices, losses, nobilities and expenses of whatever.kind or nature, in law eauity or otherwise.whether known or unknown., suspected or unsuspecteu, anticipated or unanticipaiea, which the Parties have,Ihad, or herearter may have, 3 7taoai1..9tob2 :directly or indirectly.arisma out ot in connection with.relating to or concerning in any way, the T.n=Map,we Action and line Sale. This'Release does not appiy-to any disputes concerning the City's proposed proiect to widen of Atlanta Avenue and any claims arising-from or related to the f:iry's activities in conjunction with the planned widening of A-ilanta. 3. The rariies certify that they 'nave read Civil Code § 1542, set iorth below, and indicates that fact by initialing here:-_-- _— CitY� ,[Pacific]: } Uriafat lElCiISG tiluBs 11iYi eXicliu `EU Cia1r115 'wlllii7, irsc Vre[LttGT does not know or suspect to exist in his or.her favor.at the time of ti4eimtiag. Id ielebse, 'vJ1IO, S kho-Wn by hila or her must liave materially affected his or her settlement with the debtor." 5. After reading and understanding Civil Code section 154Z the City and Pacific vuluuearily waive its application to 'this Agreemtml. The City and pae f,e understand and acknowledge that the significance and consequence of this waiver is that even if the City or Pacific snousd cveuiuslly safier addition,% damages arising out: of itre Dispute, dre City and Pacific will not be permitted to make any claim against the other Party for those damages. runhermure. the City and .3Pati is aelmowledge Thai 'dire City and kaci.uc iriend triese consequences even as to claims for darnaaes that may exist. and which, if known. would materially affect the City's and Pacifies decision to execute this Agreement regardless of 1Nffielher the Uly's or ilaci i&s lack of knowledge is the roust of ignorance, oversigb error, nealiaence.or any other cause. 7. City to agrees to process the final map of the Tract Map on a`=fast track"with the final approval of the final map completed by June 1,2013,unless the processing of the-final map -,A,as delaveil.bccause a lhta aiiu&er guVeTru►yeu"s.Ertityiagrncy w iTi uxYilYUn y lela e i to lilt clap, or by the failure of Pacific to timely.meet its obligations reaarding processing of the final man. be CSiy shah irapuzit uO %vindiiiurs on appsoviug the fWai map extept as specified iu -ibe approval of the Tract Map onNovember 19,2012. City and Pacific will stipulate to an order that provides the Court in the Subdivision Action i emi nuing jurisdiction io enforce this.ixgreement concerning the processing of the final man on a noticed motion. The June 1,2013 deadline shall be extendt;d by wTiuea agteerL'em-L of the fables at by Gider of Cuwt on a snowing the Iailure to meet the deadline was as a result of actions or inactions not attributable to the City of Huntington neacu, W she C ity iaus to appxuvt i'ne :troth soap wiihin the deadline esia`blisned IVY inis Agreement by reason of deiays caused solely by the City,City agrees to pay Pacific as liquidated da - es in the amount of S25iSi.IYO per week cif delay aitriburabie solely to fhe City based on.a mutuaIly kgreed upon schedule of performance attached hereto as Exhibit C.plus and legal fees. costs. and engineering lees incurred by Pa6he as a result o:t we City #ailing to iult its obligations under this Section. If Pacific does not submit:materials with corrections mandated to the City within i'he time irdmes esiadli:shed Schedule i;,tht:Schedule is aiicomatic aRv ad�iusied based on the actual date of submission of the materials and the deadline for the Citv to approve the Final Map is extended accordingly" 8. -Ilie pariies agree 't ml there is a toffim, of all procedural and substam ve bole frames for asserting any claims and administrative applications until July 1. 2013, provided 17 3041/91062 however, this Agreement shall not be construed in:any way to allow for or extend the time to reconsider the Tract Map. In the event there is an extension of time to approve the Final Map, !i . iva iv'uu1�a�tlwi:ii]ri1i-wiu 'a11t.{b11a'd%'auy 4YC CiGcuicu cxiriliacCi av Jd uava a1►oi &11v ilcw uir8i:c'._G established for approving the Final Map. 9. Through January 1 2018.or upon Pacific applying to the City for a change of use u die Falk, -whichtvaf ucLuis i`]Tsi, PaUEL Shall nave the 3igAii W 1liaililahl exisar;g, Yht; ie homes and related 'structures in the Huntington Right of Way_ Pacific may .replace existing ii 6bi le humt eucruaL„ ire die Huftti tor► L!&'i of W ay,pio-vides ihaY ulcre is nu expamiou pit the existing footprint Additional,non-habitable structures may be installed into the.Huntington ri'i A of v`J ay lip vo aad iudva&wg the uTca Whele lhG lemi.i5 Va"aQ fd-Y 10;;&td,k v S.T1y--Bala-U,%. Pacific may occupy the Huntington Right of Way without payment of compensation to the City 'uniii and unless'ine iiiy's use of-fine lriim mgiun Aid i of Way commences as defined in finis Agreement 10. Pacific's right to use the Huntington Right of Way to the existing fence line 'nominates (ij Sanuary 1,201`a, or 1&0 !lays after tine approval'ny'toe City of any application by Pacific for a change of use of the Park.,whichever occurs first. However:if a change of use is not approved, Pacifies right-to use the Huntington Right of Way will continue after January 1, 2018 until six (6)months following the City giving Pacific written notice of the approval of the Wilsmiddon Ui'iiie V10jei:L lu Idae launiington R`i t ui Way,U-ndei Lice itai is o1 !t-iis Agreei itri` An Application to :modifv the Tract Map, Request For Lot Lisle Adjustment or similar applications or requests which do not seek to terminate or change the use of the Park as a mobile ._._horneparicanazi-nor=�r�sdtute-srsur�,nge�i-used.c►r--lcir��it3rnosesof-this-.agreement--------_..._.__.__--.-.._._.......-.__..--_-.,--- l L Pacific agrees to defend,indemnify and hold the City Harmless for any damages to property or persons occurring in the Huntington Right of Way until the City takes possession as provided herein,including any and all claims arising:from the removal of the encroachments. 12. Prior to the temtination of Pacifies Tight to use the Huntington Right of'Vay, Pacific:shall cause the removal of any and all encroachments from the Huntington:Right of Way within six(6) months of the City approving the construction of the Project in the Huntington Right of Way (the "Approval'D or on the termination of any legal challenge to the Approval, vdiichever is later. Pacific shall bear all costs and expenses for removing any and all encroachments. The Project shall be deemed approved upon all of the following occurring; ai The City makes findings to the effect that the Project improvements,including the width.of the Project.are reasonably necessary to serve the purposes of the Project (the"Findings'').; b3 The City has given six months'notice of the adoption of the Findings,; cj Paior to the adoption of the Findings,City agrees to meet and confer with Pacific regarding the desi,pi of any Project utilizing the Huntington Right of Way and provide Pacific a reasonable opportunity to propose alternatives that would fulfill the purpose of the Project Should the City adol5t the Findings, Pacific may 17-3041191062 commence a legal action tinder CCP §1094-5 within 90 days of adoption of the yindungs to zL,&Ivagt:tie Piojeel- I-a any iegal acduu i,ililimdaued ic, 6la ieiige findings re�rdhlrg whether.3 pmC used use is rep-snrablly r_ecec�ru to fa NI the lyapuse ofl ,tie 1 loit i,a PIePQUdtI&LVt Di ;hail tit riU&Cd by the trier of fkt to review s r-Jh lind ngs and the trier of fart shall Consider fbe wi.ernative or aiiemaldves proposed'oy Pacific in making such determination;and 0 iuiy ifzgai eha1.icllge r urilnieilceei Vv7iiSitl9ty days of-Oue adopiiun of Zile ladirigs:is te.-minaiet3_bit final Judgment or dismissal. 13. f'aci is wiii provide votitc;e to any coach uw-neis,letiteis of piospecd-ve purchasers of underlining fee of the City's ows?enhip of the Right of Way and conditir�ns ofthas A resment reiaied'inerelo. i4. Pac iC shali be i3udCT Bo oWi7 gawya to pay ki.oi i iuni ibdte 10 any impioi'icmertis constructed by the City or third parties in the Hunfington Right of Way except as mnditinned by a fnt-ilrz entitlement. This}�g;e�t3iesl.'i s�;i slot preclude PaCiis.ftvxx�cllailrxcgiiig any piap►�se�i use of the Hurtingten Right of Way on grounds unrelated to -whether the City bas a valid enforceable right of way. This Section shall be cancelled and of no further force and effect upon 2atiLc applying to irce City fur any t a-tge of ust of the Eume Park. S.J. A.1Vitaioi cad--um col Agietraw. sb-4U bU- TtU-,tyl-ded ixgalilsL ilit 1Yiiobiie.duirar=Park 16. This Agreement shall be binding upon and inure to the benefit: of the parties hereto and their respective successors, assigns, officers, directors, principals, employees, subsidia,its, pmtuv eniiiies, a illw" agents hind curporaiiolls, attorneys, and repimeni idves, including any subsequent owners of Pacific Mobile Hnme Park. 17. In the event the Court is unwilling or unable to accept continuing jurisdiction for the purposes enforcing ibis Agreemenrt,the Parties stipulate Thatsuch disputes will be subject to binding arbitration by JAMS. 18. As this Agreement is intended to be a compromise of disputed claims by all parties. Nothing in this Agreement shall be construed to bean admission of liability by any party Nvith.respect to any of the issues raised in any of the proceedings specified in this Agreement 19. This Agreement shall be construed in accordance with,and all disputes governed by,the laws of the State of California,except as specifically provided for in this Agreement.. 20. Construction Hof this Agreement, Any rule of construction to the effect that any ambiguity is to be resolved against the drafting party shall not be applied.to the interpretation of this Agreement_ 6 143041491062 21- No breach of any provision of this Agreement can be waived unless it is in writing. Waiver of any one breach shall not be deemed to be a waiver of any uther'breach of the same or any other provision .hereof. This Agreement may be amended only by a written agreement executed by all of the parties. 22, This Agreement may be executed in counterparts. Facsimile signatures shall be deemed to be as effective as originals for the purposes of this stipulation: Dared: February ,2013 City of n Beach By: re son,city manager Approved as to Form: '` Dated: February.2013 -,.-� - -• Y. f s .�'Y TlvlcGrafl,City Af�ney Hated: February�,2013 Pacific Mobile Haire Park ily: Approved as to Form: Dated: February 2012 Harts King and£©ldren.LLP 13y: Mark D.Alpert Esq_ February 2013 Legacy 42680 Holdings , LLC By: February , 2013 Foothill to Summit Properties , LLC By: February , 2013 Sizable Properties , LLC By: 7 t F-3�.1??�IUCrV� p.1 R 21- No breach of any pro-vision of this Ageemea can be waived Zmless it is in uniting. Waiver of any one breach shall not be deemedto be a waiver of any otherbreach ofthe some or any outer provision bemof. Mds Agrecm=t may be amended may by a N11tic . agrwmcotexecutedby all ofthepar ies. 22. INs Ageemeot may be executrA in cavnterpart3. FacsimDe stLnatuses shall be deemed to be as e$ective ns originals for the proposes afthis sd2olatium Dated: Fdoiary�?Ul� QLr Deach red son,pity Manager J .Approved as to Form: rated: FehrumYZt _2013 t v Dated: Fsbru - �.2013 Pacific Mobile Flame Parr Approved as to ka= Dated: Febrmmy _2012 Fkt,King and Cold rxk► LLP Mmk D_Meat Esq. February , 2013 Legacy 42680 Holdings, LLC By: February , 2013 Foothill to summit Properties , LLC By: �OA�`", February , 2013 Sizable Properties , LLC By; r 7 9 t_�Ik!�f8]Ali all No breach of,any pravisica of this Agreement can be waived unless it is in 147ifhp, Waiver of any oaebreach shnll not be deemedto be a waiver of any other breach of the sue or any ather provision hereof. 'This Agreement miay be amended only by a written ag mant executed by all oftbe parties.. 22. This Agreement may be executed in counterparts. Facsimile sienatum shall be deemed to lye as effective ns Gn mats fortliepurposes ofthis stipulation. Dated: February 2013. Qtv ofHuatinston Beach By: re son,City Manager Approved as to Form F{ r" Dated: FebitryLJ'..20I3 1-7 �-�..�► _ By - -Y) # 3�: ]VicGrailz,CrtY A eeyy Dated: Febramy,�;2013 Pac`sficUbbile Home.Purk Dated:tebival& ,2032 Hart,ICiag and Coldr LLP By: Mu&D_Alpert;Esq. February. 2013 Legacy .4`2680 'Ho.l ngs, LLC By.: February , 2013 F o i7 Ia 'Summit Properties, LLC Fy: ; ebruary 2013 Sizable Properties, LLC By: 7 ' m_ Na bma& of my premium of ibis A,_zrecmcnt can be w4vea-ess it is in wag � c�mry�ne'4sear3�s'SaIl mot.�deem�33a be air cif�tril�rbrearlt uf�be mme a r=W a ffi=pmisirm Imcn£ -nis meat may be mnended imky bn a�eritt� weemmencEftaly RU a ftmPffti A m&Agmemeat.mV be exwd ed in zoo Fac!�Wns�e 6gu mm shall be deemedtoesems al xbepmpwmtfftbisSSPAaticm. Daut FcUumv 3 iSdv�Beaciii By_ Apyrov aaasmFa= .fL_2013 -41 r ::D j=uff&"McC=W City AIVAcv Dated�v_r3#Di3ifieeiiumre Am prOVrAMStDFG= f7ebruary 2013 ;Letgz�cyn4242e�Holdincgrs. LLC - Bv: February , 2D13 Foothill to Summit. Properties, LLC By: Februasv 12- , 2013 S3$able ?Propertlees, LLC 7 P 7 City of Hunt1haton Beach Thu VIM paoffla Flnal Map Arocaeafng Maetar&eitadtfia Id neN+ewe - --- c uatfdrt 61art Flnlah Matcht q - A 1 a n B 112V "AGIFIG F AL MAP PROCESM1�T� a oy. e a B t a" Pan Cnee r/t _ �2 says I rl y1911a Man 212817� k ploh chooky3a 3�`�PeTeu mi ap t>!ay Fr 2T"teli Pff 218/S3 P el"i so milk M` 8 � t 1 .,,,..«,:._,,._._......,Y_r.....:._,_.,.._.,..�., ,—...� - C! RawowAarin •- 2`� 4 G y Rovtow add - 10 days Mon 2/1 3 Fr 19;'y I f I I a 8"„ C ty fYev W iBaOy 1aip�nj< Cfly Ali i a�f I ipict�up A I M 6 ~plan Cheak 2 W�.___ �w-^ .�N �� 20 dey§ Tue Z178l13 Mdi1�l2t t ��Ilan chic�g2 Won, � - . Ravlaeelland 5"""`—`�acllioAsvtosaBn�b btn A I I , novtawpa{I if y i - a Gii"yRav ew yen'u� .. i0'�aya Bn yii'� Fn alta f I - `�"�`�ClyRevidwroe y orpZup"`` ``�` � � f on 6/t3` Maw 3-I 1 -Ih—Vl111owrf�ad'pl for Gle 4up _ -L I i �1 n 1'heck N3 -0 4!?s p nn CheckY�a 21 days 7'Ua anal 2 Tua 4Yfa112 I 4 LL •`�PaaIcgevteeraenr�tuimdpµ.. -WM.� ~70dayo� Uetl rC ManTB7 i .I..' PaaM evieaam LbmNakla l _ f -12~ CIfY t3o7eW�tii�nir"""'y" C aya Tub !B 1347Ma, �Clty Ri V3eI p I�te I I I -� CRY-RIVIEW ready for pic pup !day us 431 6 ua 4 2a/3 el1Y AaviaW reedy fo{ple'-up F 27 'I"FInn�PfnaG new ._.........._._„..,'�r.'.......�...,... 8 oya` ad4124110 FiCBlal1a ''� .yII4.., One Pl�nGjan on Pantic iev Be uhm to Mop '- �L 2 oys WBd 4419 nu 4/Z6/1 I . p Ctfia Revinos m l Bob Ito It p Al f S CII aC1Ba cLafd ndiBa M`n�fiOlTeCI�CIIa`^YY`�'K'` "r' S By9 - 8 3 Thufi 53� 1 _ u+upulaaaw.n.ew.a..e ell ylpnrsl as net{na tlnaf Cartaailnne- BI1 .. , a•vbNMb erp•tlM.nAed4 d... I I l I ,..:�.�:..._._�_,�.:..... �.........,.-., ,R.-,.......<.,.,..._.�,.. ..._ ._...:»...�».....1.. .plMafiteteWN#0lk h'.1 �� FfnNMaptdahnfdallyddmplpts dB �nfi1811a FnWW18 zh•�+"'d"y"B^'s."(narks 1nalMa lee nlaallycdmpfataa BIS'"' Y � fn•een.Tc aalul br oM.�+.enrw:b f 1 t faraekeq eer.udwueafine s:i.Mdw _ ItYCLUnC APPfoVfi1 -'- -„,.�....r....,...,�.....,«��i�y6^' an6l6HC MdnB12C11� f fwlMW.aenm•Mdd..Sdtl�•d..ern. �CyCeunollAprova 6110 fh.eNw•r raw G.rle ewndee Ili I r I � ddue as mnfetra"� �' 1 ddydBy Mort5r� Mon—113 I RCApI a to ad Into Ion a NOW Glly OWWO dfltce -- -- Wa 91fi1i8 waq fi e7 � Re A le elf yy{alark'B awed d B1a' 3"".'�C(IyCounctlApprddval u.....,� - 1ddy��Mci161Ibf13 Map"h10f �� _ -- - `� '-Oil, un'l1AIpro o I - p e 1 1 i 1 - —• P.W i SM171/Re E{1 t