HomeMy WebLinkAboutResolution - 2008-R0262 - Comprehensive Settlement Agreement - Choctaw Partners - 07_22_2008Resolution No. 2008—RO262
July 22, 2008
Item No. 5.12
RESOLUTION
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF LUBBOCK:
THAT the Mayor of the City of Lubbock BE and is hereby authorized and
directed to execute for and on behalf of the City of Lubbock a Comprehensive Settlement
Agreement and Release of Claims by and between the City of Lubbock and Choctaw
Partners, a Texas General Partnership, the Estate of Joe J. Reynolds, J.A.R., Inc., a Texas
Business Corporation, Jeffrey C. Reynolds, Anisse B. Reynolds and Billy David
Turrentine, Jr. which is attached hereto and which shall be spread upon the minutes of the
Council and as spread upon the minutes of this Council shall constitute and be a part of
this Resolution as if fully copied herein in detail.
Passed by the City Council this 22nd
ATTEST:
Rebe ca Garza, City Secretary
APPROVED AS TO CONTENT:
Gary Zheng,
Director of Electric Utilities
APPROVED AS TO FORM:
Ma hew L. Wade
Natural Resources Attorney
mlw/cedocs/Settlement Resolution Choctaw -City 071608
day of July , 2008.
e�
/;ZE-
Tom Martin, Mayor
Resolution No. 2008—RO262
COMPROMISE SETTLEMENT AGREEMENT
AND RELEASE OF CLAIMS
This Compromise Settlement Agreement and Release of Claims ("Settlement
Agreement") is by and between the City of Lubbock, a Texas home -rule municipal
corporation (hereinafter referred to as the "City"), 'and Lubbock Power & Light
(hereinafter referred to as "LP&L"), and Choctaw Partners, a Texas General Partnership,
(hereinafter referred .to as "Choctaw") and the Estate of Joe J. Reynolds, Deceased, acting
by and through its Independent Executor, Jeffrey C. Reynolds (hereinafter referred to as
the "Estate") J.A.R., Inc., a Texas Business Corporation, (hereinafter referred to as
"JAR'), acting by and through its President, Jeff Reynolds, and Jeffrey C. Reynolds,
Individually, and Anisse B. Reynolds (hereinafter referred to as "Anisse") and Billy
David Turrentine, Jr. (hereinafter referred to as "Turrentine") (collectively referred to as
the "Parties").
WITNESSETH
WHEREAS, Lubbock Power & Light is the municipally owned electric utility of
the City (all references herein to the "City" encompass and include "LP&L" as well); and
WHEREAS, the City and Choctaw entered into a Gas Purchase Contract
(hereinafter referred to as the "Contract") on December 8, 1988 to supply natural gas to
LP&L; and
WHEREAS, Choctaw is a Texas General Partnership whose original partners
composed of Joe J. Reynolds and David Turrentine as of the execution date of the
Contract; and
WHEREAS, JAR became a partner in Choctaw after the date of execution of the
Contract; and
WHEREAS, Choctaw granted in the favor of the City a Deed of Trust in the oil
and gas leasehold estate owned by Choctaw (herein the "Property") as recorded in
Volume 180, Page 774, Real Property Records of Cochran County, Texas as security for
performance of the Contract (hereinafter referred to as the "Deed of Trust"); and
WHEREAS, Jeffrey C. Reynolds was appointed the executor of the Estate of Joe
J. Reynolds, Deceased after Joe J. Reynolds passed away in 2004; and
WHEREAS, a dispute has arisen relative to the terms and meaning of the
Contract; and
WHEREAS, the City, Choctaw, the Estate, JAR, Anisse and Turrentine are
willing to settle all claims to avoid the inconvenience, distractions, uncertainties, and
Page 1 of 14
expenses attendant to litigation and trial, in exchange for the consideration and releases
set forth below; and
WHEREAS, Turrentine has agreed to transfer, sell and convey all of his interest
in and to the Contract, Choctaw Partners, or any other interest as set forth in a Partnership
Sales Agreement between Turrentine, Anisse, JAR, and the Estate.
NOW THEREFORE, the parties hereto agree as follows:
1. As consideration for entering this Settlement Agreement, Choctaw, the
Estate, JAR, Anisse, and Turrentine do hereby release, acquit, and forever discharge the
City from any and all contractual liability, claims, demands, damages, attorney's fees,
costs, liens, whether statutorily provided or otherwise, expenses, services, actions, causes
of action, or suit in equity, of whatsoever kind or nature, whether heretofore or hereafter
accruing, arising out of the Contract, or any dispute related thereto, by and between the
City and Choctaw.
2. As consideration for entering into this Settlement Agreement and the
payment to be made by Choctaw and the Estate, the City and LP&L do hereby release,
acquit and forever discharge Choctaw, the Estate, JAR, Jeffrey C. Reynolds, Individually
and in all capacities, Anisse and Turrentine, their heirs, executors, successors, and assigns
from any and all contractual liability, claims, demands, damages, attorney's fees, costs,
liens, whether statutorily provided or otherwise, expenses, services, actions, causes of
action, or any claim to any oil, gas other minerals or any and all other rights in and to the
Property or that could be claimed or otherwise asserted as a result of the Contract, or any
breach thereof, or suit in equity, of whatsoever kind of nature, whether heretofore or
hereafter accruing, arising out of the Contract by and between the City and Choctaw, or
any dispute related thereto. The City further acknowledges and agrees that the obligation
to pay such sums is the obligation of Choctaw, JAR, and the Estate only; and not
Turrentine, Jeffrey C. Reynolds, Individually, or Anisse, Individually.
3. As further consideration for entering this Settlement Agreement, Choctaw
and the Estate, jointly and severally, agree to pay to the City, by and through its electric
utility, LP&L, SEVEN HUNDRED AND FIFTY THOUSAND and NO/100 DOLLARS
($750,000.00), in accordance with the terms and conditions outlined as follows:
a). Upon final execution and delivery of this Settlement Agreement by all
Parties, Choctaw and the Estate agree to pay to the City THREE HUNDRED
AND SEVENTY-FIVE THOUSAND and NO/100 DOLLARS ($375,000.00) in
cash (or its equivalent) or by check made payable to Lubbock Power & Light; and
b). Choctaw and the Estate agree to pay to LP&L the remaining THREE
HUNDRED AND SEVENTY-FIVE THOUSAND and N0/100 DOLLARS
($375,000.00) in equal monthly installments of TWELVE THOUSAND FIVE
HUNDRED and NO/100 DOLLARS ($12,500.00) commencing on the I" day of
August, 2008, and continuing on the first day of each month thereafter for a total
Page 2 of 14
of thirty (30) months. Subject to the terms and conditions further outlined in this
Settlement Agreement, such payments shall bear no interest.
4. Each installment outlined in Section 2(b) above must be received by
LP&L by the first (0) day of the month beginning August 1, 2008. If the first (P) day
of the month falls on a holiday, weekend or non -business day, then the installment shall
be due on the first business day immediately following the first (I") day of the month.
5. Choctaw and the Estate acknowledge that (i) the settlement amount as set
forth above in this Settlement Agreement is true and correct in all respects without the
necessity of any further proof or presentation by the City or LP&L and (ii) the obligation
to pay the amount outlined herein is a contractual obligation on the part of Choctaw and
the Estate.
6. Choctaw and the Estate shall be in default ("event of default") if any one
or more of the following events shall occur:
a). Either Choctaw or the Estate fails to pay, within ten days when due any
payment set forth above;
b). Choctaw or the Estate defaults in the performance of any of the covenants
or agreements contained in this Settlement Agreement; or
c). Choctaw, or the Estate (i) is adjudicated a bankrupt, insolvent, files a
voluntary petition for bankruptcy, or admits in writing that Choctaw is unable to
pay Choctaw's debts as they become due; (ii) makes a general assignment for the
benefit of creditors; (iii) files a petition or answer seeking reorganization or an
arrangement with creditors or to take advantage of any bankruptcy or insolvency;
or (iv) files an answer admitting the material allegations of, or consent to, or
default in answering, a petition filed against Choctaw in any bankruptcy,
proceeding for the purpose of effecting any of the foregoing.
7. If an event of default occurs, the City may, at it's option, (i) declare all
unpaid amounts due hereunder immediately due and without further notice to either
Choctaw or the Estate; and/or (ii) exercise any and all rights available to it in law, equity,
contract or otherwise.
8. Any and all payments not paid when due shall bear interest at ten percent
(10%) per annum, except as provided otherwise by law.
9. Regardless of any provision herein to the contrary, in no contingency or
event shall it ever be deemed that the City has contracted for or be entitled to receive,
collect or apply as interest on the balances an amount which exceeds the maximum
amount permissible under applicable law. If, from any circumstances whatsoever,
fulfillment of any provision of this Settlement Agreement at the time the performance is
due would exceed the usury limit prescribed by law, then the obligation to be fulfilled
shall be reduced to that limit. If from any circumstances the City shall receive as interest
an amount that would exceed the highest lawful rate, the amount that would be excessive
Page 3 of 14
interest shall be applied to the reduction of the principal amount owing under this
Agreement, or shall be refunded, but shall not be applied to payment of interest.
10. Choctaw and the Estate shall be jointly and severally liable for each and
every obligation outlined in this Settlement Agreement. Any default or failure on the part
of Choctaw or the Estate shall be deemed a default or failure on the other without further
evidence or proof being presented by the City.
11. Choctaw and the Estate agree to extend, renew, modify, confirm, and/or
amend the Deed of Trust in favor of the City as security for performance of this
Settlement Agreement by Choctaw and the Estate. Furthermore, Choctaw and the Estate
agree to execute any and all documents necessary to properly record and effect this
security for performance, including, without limitation, the documents attached hereto as
Exhibit(s) A.
12 The City and LP&L, by entering into this Settlement Agreement: (i)
acknowledge that this settlement is a compromise of a disputed claim as to the liability of
Choctaw and the Estate for the City's contractual claims and damages, including a claim
for attorneys fees incurred by the City, if any, and the payment made herein is not to be
construed as an admission of liability on the part of Choctaw or the Estate. It is
understood that the existence of any liability or wrongdoing has been, and continues to
be, expressly denied by Choctaw and the Estate; and (ii) represent and warrant LP&L is a
division of the City, is not a separate legal entity, and all claims against any and all of the
parties to this Agreement relative to or arising out of the Contract are solely held by the
City.
13. The terms of this Settlement Agreement shall inure to the benefit of, and
be binding upon Choctaw, the Estate and their respective legal representatives,
successors, or assigns. All representations and warranties set forth herein shall survive
any and all closing.
14. All signatories to this Settlement Agreement hereby represent and warrant
that they have the authority to execute this Settlement Agreement and bind the respective
parties.
15. This Settlement Agreement states the entire agreement of the Parties with
respect to the matters discussed herein, and supersedes all prior or contemporaneous oral
or written understandings, agreements, statements, or promises.
16. If this Settlement Agreement does not become effective for any reason, it
shall be deemed negotiations for settlement purposes only and will not be admissible in
evidence or usable for any purposes whatsoever.
17. If any provision of this Settlement Agreement is ever held to be invalid or
ineffective by any court of competent Jurisdiction with respect to any person or
circumstances, the remainder of this Settlement Agreement and the application of such
Page 4 of 14
provision to persons and/or circumstances other than those with respect to which it is held
invalid or ineffective shall not be affected thereby.
18. No amendment, modification, or alteration of the terms of this Settlement
Agreement shall be binding unless such amendment, modification, or alteration is in
writing, dated subsequent to this Settlement Agreement, and duly executed by all of the
Parties.
19. Each party to this Settlement Agreement acknowledges and agrees that
they have obtained legal representation and advice as they have deemed appropriate in
entering into this Settlement Agreement.
20. Each party further states that this Settlement Agreement, including the
foregoing release, has been carefully read and each party understands the contents thereof
and has signed the same as their own respective free act, and has not been influenced in
making this settlement by any representative of a party or parties released.
21. It is further understood that the provisions of this Settlement
Agreement are contractual and not mere recitals, and that the laws of the State of
Texas shall govern this Settlement Agreement and that venue for any action arising
out of or related to this Settlement Agreement and the claims associated therewith
shall lie exclusively in Lubbock County.
Page 5 of 14
EXECUTED this 22nd day of July , 2008.
CHOCTAW PARTNERS
Prin d e:
For and on behalf of the Estate of Joe J.
Reynolds, Deceased, a general partner of
Choctaw Partners
STATE OF TEXAS §
COUNTY OF LUBBOCK §
Before me, the undersigned authority, personally appeared_ .J& EF=
A0 (- 4 �, for and on behalf of the Estate of Joe J. Reynolds, Deceased, a
general partner of Choctaw Partners, known to me to be the person whose name is
subscribed to the foregoing instrument and acknowledged to me that he executed the
same for the purposes and consideration therein expressed.
[SEAL]
Notary Public for the
State of Texas
ROS(NE LOVE
f Notary Public, State of Texas
My Commission Expires
8-16-2008
Page 6 of 14
CHOCTAW PARTNERS
Prin ame:_
For and on behalf of JAR Ync., a general
partner of Choctaw Partners
STATE OF TEXAS §
COUNTY OF LUBBOCK §
Before me, the undersigned authority, personally appeared 73 ; FF1
A I - Ali A
for and on behalf of JAR, Inc., a general partner of Choctaw
Partners, known to me to be the person whose name is subscribed to the foregoing
instrument and acknowledged to me that he executed the same for the purposes and
consideration therein expressed.
[SEAL]
�t ROSINE LOVE
Notary Public, State of Texas
My Commission Expires
"��'� 8-16-2008
Notary Public for the
State of Texas
Page 7 of 14
Printed effrey C. Reynolds,
Individually
STATE OF TEXAS
COUNTY OF LUBBOCK
Before me, the undersigned authority, personally appeared Jeffrey C. Reynolds,
known to me to be the person whose name is subscribed to the foregoing instrument and
acknowledged to me that he executed the same for the purposes and consideration therein
expressed.
[SEAL]
Notary Public for the
State of Texas
ROSINE LOVE
(� Notary Public, State of Texas
My Commission Expires
Page 8 of 14
d�-�
aLw.�
J.
Printed Name: Anisse B. ReynofUs
STATE OF TEXAS §
COUNTY OF LUBBOCK §
Before me, the undersigned authority, personally appeared Anisse B. Reynolds,
known to me to be the person whose name is subscribed to the foregoing instrument and
acknowledged to me that she executed the same for the purposes and consideration
therein expressed.
[SEAL]
Notary Public for the
State of Texas
a
ROSINE LOVE
Notary Public, State of TexasMy Commission Expires B-16-2008
Page 9 of 144-4
STATE OF TEXAS
COUNTY OF
Z &J.,044 �Vp-
Billy D id urrentine, r.
0
M
Before me, the undersigned authority, personally appeared Billy David
Turrentine, Jr., known to me to be the person whose name is subscribed to the foregoing
instrument and acknowledged to me that he executed the same for the purposes and
consideration therein expressed.
L `i TAMMY W. TARANGO k
Notary Public, State of Texas Notary Publil for the
.j My Commission Expires
OiSE,,� August 08, 2010 State of Texas
i/Iillt�
Page 10 of 14
ESTATE OF JOE J. REYNOLDS,
DECEAS D
Pri ed e: Jeffrey C. Reynolds
Independent Executor of
the Estate of Joe J. Reynolds, Deceased
STATE OF TEXAS §
COUNTY OF LUBBOCK §
Before me, the undersigned authority, personally appeared Jeffrey C. Reynolds,
Independent Executor of the Estate of Joe J. Reynolds, Deceased, known to me to be the
person whose name is subscribed to the foregoing instrument and acknowledged to me
that he executed the same for the purposes and consideration therein expressed.
[SEAL]
ROSiNE LOVE
®i Notary Public, State of Texas
My Commission Expires
��OF� B-16-2008
Notary Public for the
State of Texas
Page 11 of 14
CITY OF LUBBOCK
By:
Tom Martin, Mayor
STATE OF TEXAS
COUNTY OF LUBBOCK
Before me, the undersigned authority, personally appeared Tom Martin, Ma oar of
the CITY OF LUBBOCK, known to me to be the person whose name is subscribed to the
foregoing instrument and acknowledged to me that he executed the same for the purposes
and consideration therein expressed.
SEAL
Notary Public for the
State of Texas
�Ut PRY PU�' ELISA SMCHEZ
Notary Public, Shale of Texas
My Commission Expires 11-07-21i11
Page 12 of 14
CITY OF LUBBOCK
LUBBOCK POWER & LIGHT
LI-N
STATE OF TEXAS §
COUNTY OF LUBBOCK §
W.R. COLLIER
Chairman, Electric Utility Board
Before me, the undersigned authority, personally appeared W.R. COLLIER,
known to me to be the person whose name is subscribed to the foregoing instrument and
acknowledged to me that she executed the same for the purposes and consideration
therein expressed.
[SEAL]
Notary Public for the
State of Texas
AS TO FORM AND CONTENT:
for Jeffrey C. Reynolds
STEPHEN T. KRIER
Attorney for the Estate of Joe J.
Attorney for the City of Lubbock, Lubbock Power & Light
MATTHEW WADE
Attorney for the City of Lubbock, Lubbock Power & Light
RUDO PH A. WOERNDLE
Attorney for Billy David Turrentine Jr.
Page 13 of 14
Jul 21 2008 11:07RM Rudolph R Woerndle P C
4325701560 p.4
STATE OF TEXAS §
COUNTY OF LUBBOCK §
CITY OF LUBBOCK
LUBBOCK POWER & LIGHT
By:
W.R. COLLIER
Chairman, Electric Utility Board
Before me, the undersigned authority, personally appeared W.R. COLLIER,
known to me to be the person whose name is subscribed to the foregoing instrument and
acknowledged to me that she executed the same for the purposes and consideration
therein expressed.
[SEAL]
Notary Public for the
State of Texas
AS TO F AN CONTENT:
M
Atto ey for Je y C. Reynolds
1-
S T. KRIER
Atto ey for the Estate of Joe J. Reynolds
J CK McCUTC
�_ rney r the City of Lubbock, Lubbock Power & Light
MA HEW WADE
Attorney for the City of Lubbock, Lubbock Power & Light
RUDOLPH A. WOERNDLE
Attorney for Billy David Turrentine Jr.
Page 13 of 14
CITY OF LUBBOCK
LUBBOCK POWER & LIGHT
By:
W.R. COLLIER
Chairman, Electric Utility Board
STATE OF TEXAS
COUNTY OF LUBBOCK
Before me, the undersigned authority, personally appeared W.R. COLLIER,
known to me to be the person whose name is subscribed to the foregoing instrument and
acknowledged to me that she executed the same for the purposes and consideration
therein expressed.
INIHI
r, ��; ► ;�o
• n
OLIVIA PIERCE
Notary Public. State of Texas
[SEA
�;�s
My Commission Expires
September 15, 2006
�►
Notary Public for the
State of Texas
APPROVED AS TO FORM AND CONTENT:
NOLAN GREAK
Attorney for Choctaw Partnership
STEPHEN T. KRIER
Attorney for the Estat2of e J. Reyno
JrKMcCUTCH .
Aey for the City of Lubbock, Lubbock Power &Light
M!�� &�04
MA THEW WADE
Attorney for the City of Lubbock, Lubbock Power & Light
Page 13 of 14
CITY OF LUBBOCK
LUBBOCK POWER & LIGHT
By:
W.R. COLLIER
Chairman, Electric Utility Board
STATE OF TEXAS §
COUNTY OF LUBBOCK §
Before me, the undersigned authority, personally appeared W.R. COLLIER,
known to me to be the person whose name is subscribed to the foregoing instrument and
acknowledged to me that she executed the same for the purposes and consideration
therein expressed.
[SEAL]
Notary Public for the
State of Texas
APPROVED AS O FORM AND CONTENT:
NO AN GAEAM.
Att mey for Jeffrey C. Reynolds
STEPHEN T. KRIER
Attorney for the Estate of Joe J. Reyno1 ;5�ld
JA K McCUTCHIN
orney f r the City of Lubbock, Lubbock Power & Light
Z�cr.04—
MATtHEW WADE
Attorney for the City of Lubbock, Lubbock Power & Light
Page 13 of 15
RujJbLP14 A. WOERNDLE
Attorney for Billy David Turrentine Jr.
Page 14 of 15
Attachments: Exhibit A — Amendment, Modification, Ratification and Confirmation of
Deed of Trust
Page 15 of 15
Resolution No. 2008-RO262
Exhibit "A"
AMENDMENT, MODIFICATION, RATIFICATION AND
CONFIRMATION OF DEED OF TRUST
STATE OF TEXAS
KNOW ALL MEN BY THESE PRESENTS:
COUNTY OF COCHRAN
WHEREAS, on December 8, 1988, Choctaw Partners, a Texas General
Partnership (the "Grantor"), executed that certain Deed of Trust (the "Deed of Trust")
encumbering the property described in the Deed of Trust; and
WHEREAS, the Deed of Trust is recorded in Volume 180, Page 774, Real
Property Records, Cochran County, Texas; and
WHEREAS, the City of Lubbock was named the beneficiary in the Deed of Trust
(the" Beneficiary"); and
WHEREAS, the Grantor and the Beneficiary desire to renew, extend, amend and
modify the Deed of Trust, including, but not limited to the obligations expressly secured
by the Deed of Trust, including but not limited to those outlined in Article II of the Deed
of Trust, and desire for the Deed of Trust to specifically secure such obligations outlined
in Article II of the Deed of Trust;
NOW, THEREFORE, for good and valuable consideration, the receipt and
sufficiency of which is expressly acknowledged, Borrower and Bank hereby agree as
follows:
1. The Secured Indebtedness secured by the Deed of Trust, namely Article II
on page 2 of such Deed of Trust, shall be amended by deleting Section 2 in its entirety
and replaced with the following::
"Section 2. This Deed of Trust is given to secure the obligations of
Grantor to perform the obligations imposed on it in the "Compromise
Settlement Agreement and Release of Claims" dated the day of July,
2008."
2. It is expressly agreed by the Grantor and the Beneficiary that all terms of
the Deed of Trust not above modified and/or amended shall remain in full force and
effect as written therein.
3. Grantor ratifies the Deed of Trust as herein modified and amended and
confirms that the Deed of Trust is in full force and effect, is fully enforceable, and creates
a valid lien in favor of the Beneficiary upon all of the property described therein.
EXECUTED this day of , 2008.
Page 1 of 3
CHOCTAW PARTNERSHIP
Printed Name: Jeffrey C. Reynolds,
President
For and on behalf of the Estate of Joe J.
Reynolds, a general partner of Choctaw
Partnership
STATE OF TEXAS §
COUNTY OF LUBBOCK §
Before me, the undersigned authority, personally appeared Jeffrey C. Reynolds,
President, for and on behalf of the Estate of Joe J. Reynolds, a general partner of
Choctaw Partnership, known to me to be the person whose name is subscribed to the
foregoing instrument and acknowledged to me that he executed the same for the purposes
and consideration therein expressed.
[SEAL]
Notary Public for the
State of Texas
Page 2 of 3
CHOCTAW PARTNERSHIP
Printed Name: Jeffrey C. Reynolds,
President
For and on behalf of the JAR Inc., a general
partner of Choctaw Partnership
STATE OF TEXAS §
COUNTY OF LUBBOCK §
Before me, the undersigned authority, personally appeared Jeffrey C. Reynolds,
President, for and on behalf of JAR Inc., a general partner of Choctaw Partnership,
known to me to be the person whose name is subscribed to the foregoing instrument and
acknowledged to me that he executed the same for the purposes and consideration therein
expressed.
[SEAL]
Notary Public for the
State of Texas
Page 3 of 3