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2011061902 - Approval Settlement - Fiedler vs TownDATE: TO: FROM: COUNCIL AGENDA REPORT September 14, 2011 MAYOR AND TOWN COUNCIL JUDITH PROPP, TOWN ATTORNEY MEETING DATE: 9/19/11 ITEM NO: SUBJECT: APPROVE SETTLEMENT AND AUTHORIZE TOWN ATTORNEY AND TOWN MANAGER TO NEGOTIATE AND EXECUTE A SETTLEMENT AGREEMENT IN FIEDLER v. TOWN OF LOS GATOS RECOMMENDATION: Approve a settlement and authorize the Town Attorney and Town Manager to negotiate and execute a settlement agreement in Fiedler v. Town of Los Gatos, Santa Clara Superior Court, Case No. 110 CV 173748. BACKGROUND: The parties have agreed to a settlement in the matter entitled Fiedler v. Town of Los Gatos (Case No. 110 CV 173748) involving a real property dispute involving a public roadway. The resolution will approve the settlement and authorize the Town Attorney and Town Manager to negotiate and execute a settlement agreement, an easement in the Town's favor and related documents to settle this matter for $72,500 and an Easement in the Town's favor. DISCUSSION: This matter was referred to mediation in April 2011. The mediation did not result in resolution in this case. Discussions between the parties continued and, the Town subsequently had a second survey of the property prepared. After considering the property surveys, Plaintiff's counsel submitted a settlement demand and Town countered. It is recommended that the settlement be accepted in the amount of $72,500, in exchange for an Easement in the Town's favor, subject to the terms and conditions negotiated by the Town Attorney. PREPARED BY: Judith Propp, Town Attorney rlY Reviewed by: ' 7-'T own Manager Assistant Town Manager Finance PAGE 2 MAYOR AND TOWN COUNCIL SUBJECT: APPROVE SETTLEMENT AND AUTHORIZE A SETTLEMENT AGREEMENT IN FIEDLER v. TOWN OF LOS GATOS (CASE NO. 110CV 173748) September 14, 2011 ENVIRONMENTAL ASSESSMENT: The recommended action is not a project as defined under CEQA, and no further action is required. FISCAL IMPACT: Approval of the funds would result in the payment of $72,500. Funds for the settlement of this case are available in the Town's Liability Programs fund. The ls` quarter budget report (November 2011) will reflect a recommended budget adjustment to account for these funds.