Contract - Paul Cates Stable, LLC - 5/14/2026 Sheets, Childs, & Sandre. PLLC
ATTORNEYS AT LAW
309 East Main street.Round Rock,TX 78664-5246
Phone 512-255-8877.fax 512-255-8986
John(oscrrlaw.com
April 9,2026
Via a-mail: keeshamontoya(a-.,,,klmontovalaw.com
Paul Cates Stable,LLC
c/o Keesha L. Montoya,Attorney at Law
1464 E.Whitestone Blvd., Suite 2402
Cedar Park,Texas 78613
SETTLEMENT AGREEMENT
Re: City of Round Rock,Texas;Gattis School Road Project—Segments 4 and 5;
Acquisition from Paul Cates Stable,LLC
Dear Ms.Montoya:
This letter will serve as a Settlement Agreement ("Agreement") between the City of Round Rock,
Texas ("City")and Paul Cates Stable, LLC (hereinafter"Cates"), (collectively the"Parties") as to the
following:
1. This Settlement Agreement is for the resolution of the above-mentioned acquisition of
real property from Cates and any associated claims.
2. This agreement is contingent on final approval by the City. In the event this Agreement is
not approved by the City and executed by an authorized representative, this agreement is
null and void and the Parties may continue as if there had never been an agreement.
3. The City agrees to pay the total compensation amount of $134,557.00 for the City's
necessary 0.169 acre fee simple acquisition,described in Exhibit"A"attached hereto(the
"Property"), any improvements situated thereon, and any damages or costs to cure the
remaining property of Cates,if any(collectively the"Property").
4. The Parties agree to settle this acquisition of the Property via a stipulated Special
Commissioners' Hearing in a condemnation proceeding filed by the City against Cates
and any additional parties with monetary liens affecting the Property,after which the City
will deposit the amount awarded by the commissioners into the registry of the Court.
Cates agrees to waive the right to file objections to a stipulated award of$134,557.00. If
the commissioners award an amount other than the stipulated amount of$134,557, then
the Parties agree to timely file objections and enter a judgment for $134,557.00, which
amount will be deposited into the registry of the Court.
12`�
5. Cates shall be notified of the hearing date once set at the discretion of City, but agrees to
waive the right to be formally served with Notice of Special Commissioners Hearing by
City. Cates also waives any and all other prerequisites as required in Chapter 21 of the
Texas Property Code for scheduling and setting up a Special Commissioners Hearing.
Cates acknowledges that a final offer will not be received because the Parties have
reached a negotiated agreement following the initial offer regarding the measure of fair
market value to be paid the fee owner for acquisition of the Property.
6. The Parties agree that$134,557.00 is the final and total compensation amount payable to
Cates and any lienholders with interests affecting the Property and is inclusive of any pre-
judgment interest. The City shall receive credit for any funds previously paid pursuant to
any PUA in this case.
7. Post judgment interest, if any, is tolled for a period of 60 days after the Court signs a
judgment in this case. If the City fails to pay the remaining balance owed after credits
from any PUA payments within the 60 days of the Court signing a judgment in this case,
then Cates shall be entitled to post judgment interest only on the remaining balance that
has not been paid at the statutory rate as of the date the judgment is signed by the Court
until paid.
8. The City's sole compensation obligation shall be the total payment of$134,557.00 for the
Property. Any compensation claims made in this case by parties to this lawsuit shall be
satisfied from this payment without further recourse to the City.
9. If any party outside of this Agreement contests compensation and/or this settlement at
any proceeding after this Agreement is fully executed, the City may terminate this
contract, and the Parties may proceed with this lawsuit as if there had never been an
agreement.
10. This Agreement may be filed as a Rule 11 agreement in any condemnation suit filed to
acquire the Property.
11. The Parties bear their own costs of court as incurred.
If this letter correctly sets forth the terms of our agreement and the settlement reached between the
City and Cates,please indicate by having the appropriate person sign this letter in the space indicated
below and return it to my attention.
Sincerely,
John L.Kelley
SBN: 24089109
JohnL`.scrrlawxom
Sheets,Childs,&Sandre,PLLC
ATTORNEY FOR
CITY OF ROUND ROCK,TEXAS
[Cates signature page follows]
2
AGREED AND ACCEPTED:
PAUL CATES STABLE,LLC
By: Elf
Name: A,/d y� s
Title: Ae le
Date:
�/- 0
Keesha L ontoya
Attome at Law
TBN: 24103883
LBN: 32906
NYSB: 6169742
1464 E.Whitestone Blvd. Suite 2402
Cedar Park,Texas 78613
Office: (512)373-4200
Fax: (512)986-7275
Cell: (737)7014382
Email: keeshamontoya(cklmontoyalaw.com
ATTORNEY FOR CATES
[The City's signature page follows]
3
AGREED AND ACCEPTED:
CITY OF ROUND ROCK,TEXAS
B
Craig Lorgan, ayor
Date: "SCS ll (�. Zo L4
4
1 Chisholm Trail:Suite 130
Round Rock,TX 7681
T o.512.80065 1 f:512.246.0359
TBPLS 10194115
stvinc.com
EXHIBIT"A"
Variable Width R.O.W. Acquisition
BEING A 0.169 ACRE TRACT OF LAND SITUATED IN THE P.A. HOLDER SURVEY,ABSTRACT NO.297,IN THE CITY
OF ROUND ROCK,WILLIAMSON COUNTY,TEXAS; AND BEING A PORTION OF A CALLED 7.50 ACRE TRACT OF
LAND DESCRIBED IN A WARRANTY DEED TO PAUL CATES STABLE, LLC, AS RECORDED IN DOCUMENT NO.
2004069084,OF THE OFFICIAL PUBLIC RECORDS OF WILLIAMSON COUNTY,TEXAS(O.P.R.W.C.T.).SAID 0.169
ACRE TRACT BEING MORE PARTICULARLY DESCRIBED BY METES AND BOUNDS AS FOLLOWS:
BEGINNING at a found 1/2-inch iron rod with red cap(illegible) marking a southeast corner of said 7.50 acre
tract said point also being at a corner of the existing north right-of-way (R.O.W.) line of Gattis School Road
(R.O.W.width varies),for the POINT OF BEGINNING and the southeast corner of the herein described tract;
THENCE, 5 88° 05' 35" W,with the common south line of said 7.50 acre tract and said existing north R.O.W.
line of Gattis School Road,a distance of 228.34 feet to a found 1/2-inch iron rod at the northeast intersection
of said Gattis School Road and Round Rock Ranch Boulevard (R.O.W.width varies),for the southwest corner
of the herein described tract;
THENCE, N 01° 53' 13"W,with the common west line of said 7.50 acre tract and the existing east R.O.W. line
of said Round Rock Ranch Boulevard,a distance of 29.11 feet to a found 1/2-inch iron rod,for the northwest
corner of the herein described tract,said point being on the proposed R.O.W. line of Gattis School Road,-
THENCE,
oad;THENCE, N 86° 31' 25" E,over and across said 7.50 acre tract with said proposed Gattis School Road R.O.W.,
a distance of 228.35 feet,to a set 5/8-inch iron rod with yellow plastic cap stamped "STV",on the common
east line of said 7.50 acre tract and the west line of a called 7.52 acre tract, less a 0.638 acre tract for
R.O.W., in a General Warranty Deed to Venu Kasam & Srinivas Veera Velli as recorded in Document No.
2021031636,O.P.R.W.C.T., same being a corner of said Gattis School Road,for the northeast corner of the
herein described tract;
THENCE, 5 02° 01' 26" E,with said 7.S0 acre tract and the existing north R.O.W. line of Gattis School Road,a
distance of 35.37 feet to the POINTOF BEGINNING and containing 0.169 acre of land,more or less.
Basis of Bearings: Bearings are based on the Texas State Coordinate System(Central Zone, NAD83)which
is based on the Trimble RTK Network.
�E0FrF
��P`�c'\ RFo'gS
2024.07.22
.......................
as A. McKoy—T LS#5799 DOUGLAS A.McKOY
....................
.•o•••5799•••�
�,9�0 S U R��`��Q
1 OF 2
EXHIBIT "A"
0' 25' 50'
1" = 50' BOLDER SURVEY
7y
X97EXAS
m
V j WILLIAM CALLED 7.52 ACRES
o 'U' c N (LESS 0.638 AC.)
I +w, =j VENU KASAM & SRINIVAS VEERA VELLI
0 CALLED 7.50 ACRES DOCUMENT NO. 2021031636
N ?0 PAUL CATES STABLE, LLC O.P.R.W.C.T.
p DOCUMENT NO. 2004069084
O.P.R.W.C.T.
ie rn Q C
O
N 86'31'25" E — 228.35' EXISTING R.O. •
CALLED 0.638 ACRES
CK P OPOSED R.O.W CITY OF ROUND ROCK
PROPOSED R.O.W. DOCUMENT NO. 2018113086
0.169 ACRE O.P.R.W.C.T.
P.J
< " C.M. REDCAP
S 88'05'35 W — 228.34 EXISTING R.O.W.
LINE TABLE c.M. ILLEGIBLE
a UNE BEARING LENGTH GATTIS SCHOOL ROAD
L1 N 01'53'13" W 29.11' (R.0.W. WIDTH VARIES)
L2 S 02'01'26" E 35.37'
a
GENERAL NOTES:
1.) ALL PROPERTY CORNERS FOUND ARE CONTROL LEGEND
MONUMENTS.
2.) SUBJECT TO ANY AND ALL COVENANTS, RESTRICTIONS, Q = CALCULATED POINT P�� TFC
EASEMENTS AND CONDITIONS THAT MAY BE APPLICABLE. O = 5/8" IRON ROD WITH YELLOW CAP STAMPED "STV" SET 5�Q�cG1Rl�p�S
3.) THE SURVEYOR DID NOT ABSTRACT THE SUBJECT TRACT.
THERE MAY BE ADDITIONAL EASEMENTS OR R.O.W. THAT 0 = 1/2" IRON ROD WITH CAP "AS NOTED" FOUND „. .........
AFFECT THE SUBJECT TRACT. * = 1/2" IRON ROD FOUND DOUGLAS A.McKOY
4.) THIS DRAWING IS ACCOMPANIED BY A METES AND ".f""
p BOUNDS DESCRIPTION. O.P.R.W.C.T. - OFFICIAL PUBLIC RECORDS OF WILLIAMSON COUNTY, TEXAS ;a 5799
5.) BEARINGS ARE BASED ON THE TEXAS COORDINATE P.O.B. = POINT OF BEGINNING �y'9OREg$10�;p'pQ
SYSTEM (CENTRAL ZONE, NAD83) WHICH IS BASED ON C.M. = CONTROLING MONUMENT �0'SU RV s
TRIMBLE'S CENTRAL TEXAS GPS COOPERATIVE CORS RTK
NETWORK. PAGE 2 of 2
To the best of my knowledge, information, and belief, the plat hereon is a correct
1 Chisholm Trail,Suite 130 representation of the property as determined by a survey made on the ground June 15,
StN V Round Rock,Texas 78681 512.248.0065
2024, the lines and dimensions of said property being bj indicate%btthnisplat. This
TEXAS REGISTERED ENGINEERING FIRM F-1741 survey substantially complies with the current Texas Soci of SurveyorsTBPLS 10194115 standards and specifications. 2024.07.22
Date: July 22, 2024 S ANO.5799
WORK ORDER 23oo5so DIGITAL FILE PROP ROW 0.169 AC.DWG Revision # X DRAWN BY DLM
0 2024 ALL RIGHTS RESERVED