HomeMy WebLinkAboutR23-618377
RESOLUTION R23-618
A RESOLUTION AUTHORIZING THE CITY MANAGER EXECUTE A
SETTLEMENT AND ASSIGNMENT OF CLAIMS WITH A
SUBCONTRACTOR WHO PROVIDED WORK ON THE PLAINVIEW
AQUATIC CENTER PROJECT.
WHEREAS, City of Plainview entered into a written construction contract with
USA Management, LLC d/b/a USA Construction, LLC ("USA Management") on or about
January 17, 2019 (the "Contract") where USA Management was to act as prime
contractor in constructing the Plainview Aquatic Center in Hale County, Texas
("Project"); and
WHEREAS, USA Management hired the following subcontractor, Plains Plate
Glass & Mirror Co., to perform certain construction work related to Project; and
WHEREAS, the above named subcontractor satisfactorily provided labor and
services for the Project and assert that USA Management was invoiced for the services
provided by the subcontractor in the amounts outlined below but USA Management, to
date, failed to pay the subcontractor for the services provided:
Plains Plate Glass & Mirror Co. - $4,423.83
WHEREAS, despite USA Management's failure to pay subcontractor for
satisfactorily providing the services for the Project, the subcontractor continued to
cooperate with and assist the City in completing the Project even after USA Management
abandoned the job site so that the Project could be opened for public use by the citizens
of Plainview in a timely manner; and
WHEREAS, the City Council of the City of Plainview, recognizing the satisfactory
work provided by the above referenced subcontractor and recognizing the additional
work provided by such subcontractor so that the City of Plainview could open the
Plainview Aquatic Center to the citizens of Plainview after USA Management stopped
working on the Project, believes it to be in the best interest of the City of Plainview to
settle the claims of the above referenced subcontractor by paying the amounts of the
unpaid invoices and having the subcontractor assign their legal claims against USA
Management to the City of Plainview;
NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
PLAINVIEW, THAT:
1. The recitals outlined above are found to be true and correct and are hereby
adopted.
2. In exchange for the above -mentioned contractors executing a settlement
agreement and assignment of claims, the basic form of which is attached hereto and
incorporated herein, the City Manager is authorized to remit to the subcontractor funds
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for the unpaid invoices of such subcontractor for work provided for the Project in the
amounts referenced above.
3. The City Manager, after consultation with the City Attorney, may modify or amend
the form of the settlement agreement and assignment of claims if requested by the
subcontractor or their legal representatives so long as the substantive terms and amount
paid to the subcontractor remain the same and the legal rights of the City of Plainview are
protected.
PASSED AND APPROVED this 12th day of December. 2023.
ATTEST:
&Wl�?(
Belinda Hinojo ity Secretary
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Resolution R23-618
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ASSIGNMENT OF CLAIMS
This Assignment of Claims (this "Assignment") is made on this the day of
, 2023, by and between Plains Plate Glass & Minor Co.., located at 215 E
5th St Plainview, Texas 79072 ("Assignor"), and the City of Plainview, Texas ("Assignee" or "City").
RECITALS
WHEREAS, Assignee entered into a written construction contract with USA Management, LLC
d/b/a USA Construction, LLC ("USA Management") on or about January 17, 2019 (the "Contract") where
USA Management was to act as prime contractor in constructing the Plainview Aquatic Center in Hale
County, Texas ("Project"); and
WHEREAS, USA Management hired Assignor to perform certain construction work related to
Project which included the following services: Installation of Two (2) 40x52 sliding service windows,
two (2) 52x52 slidiniz service windows, one (1) 120x56 stationary window, one (1) 48x 56 stationary
window, and three (3) 32 x 6 vision panels in walk-in doors. ; and
WHEREAS, Assignor satisfactorily provided such services and asserts that USA Management
was invoiced for the services provided by Assignor but USA Management, to date, has not paid Assignor
for the services provided;
WHEREAS, in spite of USA Management's failure to pay Assignor for satisfactorily providing
the services outlined above, Assignor continued to cooperate with and assist the City in completing the
Project after USA Management abandoned the job site so that the Project could be opened for public use
by the citizens of Plainview in a timely manner; NOW THEREFORE:
AGREEMENT
1. For valuable consideration, the receipt and sufficiency of which is hereby acknowledged, Assignor
assigns and transfers to Assignee any and all claims, demands, liabilities, obligations, damages, actions, or
causes of action of any kind and every nature whatsoever which Assignor has, has ever had, or may have
in the future, whether known or unknown at the date of this Assignment, against USA Management, LLC
d/b/a USA Construction, LLC, or any other person or persons, whether jointly or severally, arising out of,
or for, any loss, injury, or damage sustained by Assignor in connection with the Project ("Claims")
including all Claims that may be asserted in the lawsuit currently styled City of Plainview v. USA
Management, LLC; Cause No. B44456-2209 in the 242nd Judicial District of Hale County.
2. Assignor represents and warrants that: (i) Assignor has not previously transferred, assigned or
pledged Assignor's Claims; and (ii) Assignor has the full power and authority to transfer Assignor's Claims
under the terms of this Assignment.
3. Assignor appoints Assignee and Assignee's legal representatives and assigns, with power to
demand and receive satisfaction of the Claims, and, at Assignee's expense, in the name of Assignor take
whatever legal action may be necessary to enforce the Claims.
4. Assignor shall do, execute, acknowledge, and deliver all such further acts, assignments, and other
documents reasonably requested by Assignee to fulfill the terms of this Assignment and necessary to pursue
the Claims during the time such Claims are held by Assignee.
5. Assignee and Assignor agree that (a) the assignment of Claims by Assignor as contemplated in this
Assignment is not to be construed as an admission or acknowledgment of liability, under legal or equitable
doctrines, on the part of Assignor or Assignee; and (b) no person or entity may utilize this Assignment or
the consideration received pursuant to this Assignment as evidence of any admission of liability.
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6. This assignment is without recourse, and Assignor does not guarantee payment of the Claims.
Assignor agrees, however, that in the event any payment under the Claims is made to Assignor, Assignor
will promptly transmit such payment to Assignee.
7. This Assignment shall bind and inure to the benefit of the parties and their respective successors
and assigns.
8. If any provision of this Assignment is found to violate any statute, regulation, rule, or order or
decree of any governmental authority, court, agency, or exchange, such invalidity shall not be deemed to
affect any other provision of this Assignment. If any provision is deemed invalid, it should be enforced to
the maximum extent allowed by law. If such enforcement is not possible, the invalid provision should be
deemed deleted to the minimum extent necessary to cure the violation.
9. Assignor acknowledges and agrees that they have obtained whatever legal representation and
advice as they have deemed appropriate in entering into this Assignment.
10. This agreement shall be exclusively governed by and construed according to the laws of the State
of Texas and that any conflicts of law rule requiring reference to the laws of another jurisdiction shall be
disregarded. The Assignor and Assignee agree that any lawsuit to enforce or construe this agreement shall
lie exclusively in Hale County, Texas.
ASSIGNOR
PLAINS PLATE GLASS & MIRROR CO.
STATE OF TEXAS
COUNTY OF HALE
Before me, the undersigned authority, personally appeared
of Plains Plate Glass & Mirror Co., 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.
Notary Public for the State of Texas
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STATE OF TEXAS
COUNTY OF HALE
ASSIGNEE
CITY OF PLAINVIEW, TEXAS
Jeffrey Snyder, City Manager
Date:
Before me, the undersigned authority, personally appeared Jeffrey Snyder, 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.
Notary Public for the State of Texas
1
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COMPROMISE SETTLEMENT AGREEMENT
AND RELEASE OF CLAIMS
This Compromise Settlement Agreement and Release of All Claims ("Settlement Agreement") is by and
between the City of Plainview a home rule municipality and political subdivision of the State of Texas ("City") and
Plains Plate Glass & Mirror Co. whose place of business is located at 215 E 51 St., Plainview, Texas
79072 ("Claimant" or "Plains Plate Glass & Mirror Co.") (collectively referred to as the "Parties").
WITNESSETH
WHEREAS, the City entered into a written construction contract with USA Management, LLC d/b/a USA
Construction, LLC ("USA Management") on or about January 17, 2019 ("Contract") where USA Management
was to act as prime contractor in constructing the Plainview Aquatic Center in Hale County, Texas ("Project");
and
WHEREAS, USA Management hired Plains Plate Glass & Mirror Co. to perform certain construction
work related to Project which included the following services: Installation of Two (2) 40x52 sliding service
windows, two (2) 52x52 sliding service windows, one (1) 120x56 stationary window, one (1) 48x 56 stationary
window, and three (3) 32 x 6 vision panels in walk-in doors.; and
WHEREAS, Plains Plate Glass & Mirror Co. satisfactorily provided such services and asserts that USA
Management was invoiced for the services provided by Plains Plate Glass & Mirror Co. but USA Management,
to date, has not paid Plains Plate Glass & Mirror Co. for the services provided; and
WHEREAS, Plains Plate Glass & Mirror Co. satisfactorily provided such services and asserts that USA
Management was invoiced for the services provided by Plains Plate Glass & Mirror Co. but USA Management,
to date, has not paid Plains Plate Glass & Mirror Co. for the services provided;
WHEREAS, the City denies any liability to Claimant for any claim or cause of action associated with the
above -referenced matter but is willing to settle all claims to avoid the inconvenience, distractions, uncertainties,
and expenses attendant to litigation and trial, in exchange for the consideration and releases set forth below.
RECITALS
NOW THEREFORE, for good and valuable consideration, the receipt and sufficiency of which is hereby
acknowledged by the Parties to this Settlement Agreement, the City and Claimant agree as follows:
1. The City hereby agrees to pay to Claimant, FOUR THOUSAND FOUR HUNDRED TWENTY THREE
DOLLARS AND 83/100 DOLLARS ($4,423.83) for any and all claims, invoices, unpaid invoices
damages allegedly made by the City or City's contractor USA Management to Claimant, Claimant's
Property, and any associated or ancillary equipment or personal property owned by Claimant and related to
or otherwise associated with the Project or the work the Claimant performed for the Project.
2. For the consideration set forth herein, the receipt and sufficiency of which is hereby acknowledged,
Claimant:
a. hereby forever and irrevocably, releases and acquits and discharges the City and it's respective
officers, employees, council members, managers, directors, successors, assigns and legal
representatives of and from any and all 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, accrued as of the date of the execution of this Settlement
Agreement, which the Claimant now has or may hereafter have, whether known or unknown,
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arising out of the activities outlined in the above recited matter or in any way related to the Project;
and
b. agrees to assign and transfer to the City any and all claims, demands, liabilities, obligations,
damages, actions, or causes of action of any kind and every nature whatsoever which Claimant has,
has ever had, or may have in the future, whether known or unknown at the date of this Settlement
Agreement, against USA Management or any other person or persons, whether jointly or severally,
arising out of, or for, any loss, injury, or damage sustained by Claimant in connection with the
Project including any claims which may be asserted in the lawsuit currently styled City of Plainview
v. USA Management, LLC; Cause No. B44456-2209 in the 242nd Judicial District of Hale County
and further agrees to evidence this assignment and transfer by executing an assignment of claims
in favor of the City by written instrument in form satisfactory to the City.
3. Plains Plate Glass & Mirror Co., as the Claimant, hereby represents and warrants that Plains Plate Glass &
Mirror Co. and Plains Plate Glass & Mirror Co. alone, owns the claimed rights, interests, demands, actions,
or causes of action, obligations, or any other matter covered by this Settlement Agreement ("Plains Plate
Glass & Mirror Co.'s Claimed Rights"), and that Plains Plate Glass & Mirror Co., except as specifically
outlined and provided for in this Settlement Agreement, has not transferred, conveyed, pledged, assigned,
or made any other disposition of Plains Plate Glass & Mirror Co.'s Claimed Rights. The Claimant agrees
to indemnify and hold harmless the City and it's respective officers, employees, council members,
managers, directors, successors, assigns and legal representatives from and against any and all costs,
damages, liabilities, claims, demands, or causes of action and the reasonable and necessary costs, including
attorneys' fees, incurred in the defense of any such claim that any person who claims an ownership,
including any liens whether statutory or otherwise, in Plains Plate Glass & Mirror Co.'s Claimed Rights.
4. Claimant hereby declares that he fully understands the terms of the release outlined herein and voluntarily
accepts the consideration outlined in this Settlement Agreement for the purposes of making full and final
settlement of any and all the injuries, claims, damages, expenses, and inconvenience related to any claims
that may be asserted by Claimant associated with the matter recited above.
5. The provisions of this Settlement Agreement may be pled as a full and complete defense to any action,
lawsuit, or other proceeding, which may be instituted, prosecuted, or attempted for, upon, or in respect of
any of the claims released hereby. The Claimant agrees that any such proceeding would cause irreparable
injury to the City, and that any court of competent jurisdiction may enter an injunction restraining
prosecution thereof.
6. The Claimant, by entering into this Settlement Agreement, acknowledges that this settlement is a
compromise of a disputed claim as to the liability of the claims the Claimant was making against the City,
including any claim the Claimant may have had regarding any attorney's fees Claimant may have incurred,
and any payment made herein is not to be construed as an admission of liability by the City.
7. The Claimant agrees that the damages suffered by the City by reason of any breach of any provision of this
Settlement Agreement shall include not only the amount of any judgment that may be rendered against the
City or it's respective officers, employees, board members, managers, directors, successors, assigns and
legal representatives by reason of a breach of this Settlement Agreement, but shall also include all damages
suffered by them, including the cost of attorney's fees and other costs and expenses of instituting, preparing,
prosecuting, defending any action or suit resulting from a breach of this Settlement Agreement, whether
taxable or otherwise, and costs to them of attorney's fees and all other costs and expenses of instituting,
preparing, or prosecuting any counterclaim, suit, motion, or action to recover damages resulting from the
breach of this Settlement Agreement, whether taxable or otherwise.
8. 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.
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9. The terms of this Settlement Agreement shall inure to the benefit of and be binding upon the Parties and
their legal representatives, successors, or assigns.
10. 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.
11. This Settlement Agreement and the attached exhibits state the entire agreement of the parties with respect
to the matters discussed herein and supersede all prior or contemporaneous oral or written understandings,
agreements, statements, or promises.
12. 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 provision to persons and/or circumstances other than those with
respect to which it is held invalid or ineffective shall not be affected thereby.
13. 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 both Parties.
14. Nothing in this Settlement Agreement shall be construed to provide any rights or benefits whatsoever to
any party other than the City and Claimant and this Settlement Agreement, without limitation, shall not be
construed and does not waive any claim or cause of action either the City or Claimant may have against
USA Management.
15. The Parties to this Settlement Agreement acknowledge and agree that they have obtained whatever legal
representation and advice as they have deemed appropriate in entering into this Settlement Agreement.
16. The Parties each state 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.
17. 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 Hale County.
Plains Plate Glass & Mirror Co.
Date:
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STATE OF TEXAS
COUNTY OF HALE
Before me, the undersigned authority, personally appeared ,
of Plains Plate Glass & Mirror Co.., 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.
Notary Public for the State of Texas
CITY OF PLAINVIEW, TEXAS
Jeffrey Snyder, City Manager
Date:
STATE OF TEXAS
COUNTY OF HALE
Before me, the undersigned authority, personally appeared Jeffrey Snyder, 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.
Notary Public for the State of Texas
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