R-04-05-13-13H1 - 5/13/2004 RESOLUTION NO. R-04-05-13-131-11
WHEREAS, on March 10, 2003 , the City of Round Rock ("City")
entered into a contract with Fillip Construction Company, Inc .
( "Fillip") for the construction of turn lanes on Gattis School Road
from High Country Boulevard to Red Bud Lane ( "Project") , and
WHEREAS, Fillip has submitted a claim to the City for additional
costs incurred as a result of unforeseen delays in the completion of the
Project, and
WHEREAS, the City and Fillip have expressed a willingness to
settle this claim for the amount of $18, 704 . 00, and
WHEREAS, the City and Fillip desire to enter into a Settlement
Agreement and Release in regards to this matter, Now Therefore
BE IT RESOLVED BY THE COUNCIL OF THE CITY OF ROUND ROCK, TEXAS,
That the Mayor is hereby authorized and directed to execute on
behalf of the City a Settlement Agreement and Release with Fillip
Construction Company, Inc . , a copy of same being attached hereto as
Exhibit "A" and incorporated herein for all purposes .
The City Council hereby finds and declares that written notice of
the date, hour, place and subject of the meeting at which this
Resolution was adopted was posted and that such meeting was open to the
public as required by law at all times during which this Resolution and
the subject matter hereof were discussed, considered and formally acted
upon, all as required by the Open Meetings Act, Chapter 551, Texas
Government Code, as amended.
aPFDesktOp\::ODMA/WORLDOX/O:/WDOXiRESOLUTI/R40513H7..WPD/SC
RESOLVED this 13th day of May, 2004 .
L, Mayor
ity of Round Rock, Texas
T ST:
ft/Y. LA-))e lttjiv�
CHRISTINE R. MARTINEZ, City Secr tart'
2
SETTLEMENT AGREEMENT AND RELEASE
This SETTLEMENT AGREEMENT and RELEASE (the "Settlement Agreement") is
entered into this day of April, 2004, by and between City of Round Rock, a home-rule
municipal corporation ("CORR"), and Fillip Construction Company, Inc., a Texas corporation
("FILLIP"), hereinafter collectively referred to as ("Parties").
WITNESSETH:
WHEREAS, on or about March 10, 2003, the Parties entered an Agreement (the
"Agreement") wherein FILLIP agreed to commence and complete the construction of certain
improvements described as the construction of turn lanes on Gattis School Road from High
Country Boulevard to Red Bud (the "Project");
WHEREAS,the terms of the Invitation for Bid and the responsive Proposal from FILLIP
required that the Project be completed within 90 calendar days after the date of the written
Notice-to-Proceed (the "Bid Completion Term") at a cost of One Hundred Eighty-Nine
Thousand Three Hundred Eighty-Five and 67/100 Dollars ($189,385.67) (the "Agreement
Price");
WHEREAS, the terms of the Agreement actually signed by the Parties require that the
Project be completed within forty-five (45) calendar days after the date of the written Notice-to-
Proceed (the "Agreement Completion Term");
WHEREAS, on or about October 20, 2003, a written Notice-to-Proceed was issued by
the CORR;
WHEREAS, a final walk-through has been conducted by the Parties;
WHEREAS, the Contract Period was exceeded by One Hundred Eighty-Six (186) days
through no fault of FILLIP ("Delay Period");
WHEREAS, the Delay Period has increased the cost of the Project to Two Hundred
Eight Thousand Eighty-Nine and 67/100 Dollars, a difference of Eighteen Thousand Seven
Hundred Four Dollars ($18,704.00) (the "Delay Cost-);
WHEREAS, FILLIP has made a claim to CORR for the Delay Cost incurred and
associated with the Delay Period ("Delay Claim"); and
WHEREAS, the Parties have determined that it is in their respective interests to
terminate all disputes and controversies existing between them relating to the Agreement and the
Parties have negotiated and agreed to a settlement of all disputes and controversies between them
relating to the Agreement;
Page 1 of 7EXHIBIT
I
"An
C
NOW THEREFORE, in consideration of the mutual promises and covenants contained
herein, the adequacy and sufficiency of which are hereby acknowledged, and with the intent to
be legally bound hereby, the parties hereto agree as follows:
I. AGREEMENTS
1. In consideration of the total sum of Eighteen Thousand Seven Hundred Four and
No/100 Dollars ($18,704.00) paid by CORK to FILLIP, the receipt and sufficiency of which is
hereby acknowledged by FILLIP, and in consideration of the mutual agreements, conditions,
representations, warranties, recitals, covenants and statements of intention contained herein,
FILLIP hereby accepts the above-referenced payment in full settlement, compromise and release
of all claims as arising out of or in connection with the Agreement against CORR.
2. Each Party agrees that the actual term for completion of the Project was ninety
(90) days and reform the Agreement to reflect such term for completion.
3. Each Party agrees to be solely responsible for the payment of their respective
attorney's fees and all other expenses incurred on said Party's behalf as a result of or in
connection with the Settlement Agreement.
II. RELEASE BY CLAIMANTS
1. Definition. As used in this Settlement Agreement, the term "Claims" shall mean
and refer to any and all claims of any kind or character whatsoever in law or in equity, foreseen
or unforeseen, matured or unmatured, known or unknown, accrued or not accrued, including,
without limitation, claims for usury, breach of contract, libel, slander, failure to provide goods
and services, failure to act in a commercially reasonable manner, extra-contractual damages,
violations of the Texas Deceptive Trade Practices act, violations of the Texas Business and
Commerce Code, fraud, negligence, gross negligence, deceit, intentional infliction of emotional
distress, breach of any express or implied duty of good faith and fair dealing, or any other claim
or cause of action, whether arising in contract or tort. Under this definition, "Claims" includes,
BUT IS NOT LIMITED TO, any and all claims, demands, lawsuits, debts, dues, accounts,
bonds, covenants, contracts, agreements, actions, cross-actions, rights of recovery, judgments,
liabilities, obligations, losses, costs, expenses, remedies and causes of action of any nature,
whether in contract or in tort, whether based upon fraud or misrepresentation, breach of duty, or
common law, or arising or by virtue of any judicial decision, federal or state statute or regulation,
for past, present and future injuries, property or economic damage, any act or omission or claim
asserted or which could have been asserted in a cause of action filed in court, and for all other
losses and damages of any kind, including, BUT NOT LIMITED TO, the following: all actual
damages; all exemplary, punitive and statutory damages; all penalties of any kind, including but
not limited to any and all penalties for usurious interest paid, taken, received, reserved,
contracted for or demanded; damage to business reputation; lost profits or good will;
consequential damages; damages ensuing from loss of credit; and pre judgment and post-
judgment interest, costs and attorneys' fees.
Page 2 of 7
2. In consideration for the agreements of CORR, acting for and with the intention of
binding itself and its respective heirs, legal representatives, executors, administrators, successors,
assigns, receivers and trustees and all beneficiaries for whom CORR may be acting as trustee,
FILLIP hereby RELEASES, WAIVES, ACQUITS and FOREVER DISCHARGES CORR, and
its agents, servants, employees, officers, directors, shareholders, attorneys, successors, and
assigns, past and present, from any and all Claims (as defined above), which FILLIP now has,
ever had, or ever may have against CORR that arise out of the Agreement or the Delay Claim,
except for any breaches of warranties, representation or obligations expressly set forth in this
Settlement Agreement or that are required by or survive the completion of the Project.
3. In consideration for the agreements of FILLIP, acting for and with the intention of
binding itself and its respective heirs, legal representatives, executors, administrators, successors,
assigns, receivers and trustees and all beneficiaries for whom FILLIP may be acting as trustee,
CORR hereby RELEASES, WAIVES, ACQUITS and FOREVER DISCHARGES FILLIP, and
its agents, servants, employees, officers, directors, shareholders, attorneys, successors, and
assigns, past and present, from any and all Claims (as defined above), which CORR now has,
ever had, or ever may have against FILLIP that arise out of the Agreement or the Delay Claim,
except for any breaches of warranties, representation or obligations expressly set forth in this
Settlement Agreement or that are required by or survive the completion of the Project.
4. The Parties acknowledge that this Settlement Agreement is being offered as a
settlement of a Claim and is not an admission by the Parties of liability or of any other matter not
expressly addressed in this Settlement Agreement. The Parties further agree that this matter is
being settled as purely a business decision without regard to the merits of any Claim.
M. REPRESENTATIONS AND WARRANTIES
1. CORR hereby stipulates, represents and warrants to FILLIP as follows:
(a) That CORR is the current legal and beneficial owner of all Claims
released hereby and has not assigned, pledged or contracted to assign or pledge any such
Claim to any other person or entity;
(b) That the terms and provisions of this Settlement Agreement are valid,
binding and enforceable as against CORR;
(c) That CORR is adequately represented by competent counsel and
accountants of its own choosing in connection with the execution and delivery of this
Settlement Agreement and in any and all matters relating thereto;
(d) That CORR is not under any form of legal disability or incapacity at the
time that they execute this Settlement Agreement;
(e) That CORR does not owe FILLIP any fiduciary duty and that CORR has
not relied upon FILLIP in a confidential or trust relationship in entering into this
Settlement Agreement.
(f) That in executing this Settlement Agreement, CORR has relied upon its
own judgment and the advice of its own attorneys, and further, that they have not been
Page 3 of 7
induced to sign or execute this Settlement Agreement by promises, agreements or
representations not expressly stated herein; and they have freely and willingly executed
this Settlement Agreement and expressly disclaim reliance upon any facts, promises,
undertakings or representations made by FILLIP or its attorneys other than the express
agreements, stipulations, representations and warranties contained herein;
(g) That the consent of CORR to this Settlement Agreement was not procured,
obtained or induced by improper conduct, undue influence or duress;
(h) That after investigation and consultation with its attorneys, CORR agrees
that this Settlement Agreement is fair, reasonable, and supported by good, valid, and
adequate consideration;
(i) That CORR has knowledge of all relevant and material information and
facts and has been fully informed, including by advice of counsel, concerning the
existence of potential claims against FILLIP, arising from or out of the Delay Claim, in
order to make an informed and considered decision to enter into this Settlement
Agreement, and that it is CORR's intention, based on the advice of counsel, and in
exchange for the consideration recited herein, to fully and finally release all Claims that
they have against FILLIP not otherwise reserved under this Settlement Agreement;
FILLIP;0) That CORR is not in a significantly disparate bargaining position with
(k) That CORR understands and agrees to the terms and conditions of this
Settlement Agreement; and
(1) That CORR understands and intends that FILLIP rely upon these
representations and warranties in entering into this Settlement Agreement.
2. FILLIP hereby stipulates, represents and warrants to CORR as follows:
(a) That FILLIP is the current legal and beneficial owner of all Claims
released hereby and has not assigned, pledged or contracted to assign or pledge any such
Claim to any other person or entity;
(b) That the terms and provisions of this Settlement Agreement are valid,
binding and enforceable as against FILLIP;
(c) That FILLIP is adequately represented, or had an opportunity to be
represented, by competent counsel and accountants of its own choosing in connection
with the execution and delivery of this Settlement Agreement and in any and all matters
relating thereto;
(d) That FILLIP is not under any form of legal disability or incapacity at the
time that they execute this Settlement Agreement;
(e) That FILLIP does not owe CORR any fiduciary duty and that FILLIP has
not relied upon CORR in a confidential or trust relationship in entering into this
Settlement Agreement.
(f) That in executing this Settlement Agreement, FILLIP has relied upon its
own judgment and, where applicable, the advice of its own attorneys, and further, that
they have not been induced to sign or execute this Settlement Agreement by promises,
agreements or representations not expressly stated herein, and they have freely and
willingly executed this Settlement Agreement and expressly disclaim reliance upon any
Page 4 of 7
facts, promises, undertakings or representations made by CORR or its attorneys other
than the express agreements, stipulations, representations and warranties contained
herein;
(g) That the consent of FILLIP to this Settlement Agreement was not
procured, obtained or induced by improper conduct, undue influence or duress;
(h) That after investigation and consultation with its attorneys, or an
opportunity thereto, FILLIP agrees that this Settlement Agreement is fair, reasonable, and
supported by good, valid, and adequate consideration;
(i) That FILLIP has knowledge of all relevant and material information and
facts and has been fully informed, including by advice of counsel, concerning the
existence of potential Claims against CORR, arising from or out of the Delay Claim, in
order to make an informed and considered decision to enter into this Settlement
Agreement, and that it is FILLIP's intention, and in exchange for the consideration
recited herein, to fully and finally release all Claims that they have against CORR;
0) That FILLIP is not in a significantly disparate bargaining position with
CORR;
(k) That FILLIP understands and agrees to the terms and conditions of this
Settlement Agreement; and
(1) That FILLIP understands and intends that CORR rely upon these
representations and warranties in entering into this Settlement Agreement.
IV. MISCELLANEOUS PROVISIONS
1. Parties Bound. This Settlement Agreement shall be binding upon and shall inure
to the benefit of all the Parties and their respective heirs, directors, officers, shareholders,
executors, administrators, personal representatives, successors and assigns.
2. No Oral Modification. No amendment to, modification or waiver, or consent with
respect to, any provision of any of this Settlement Agreement shall be effective unless the same
shall be in writing and signed by the Party against whom enforcement of the amendment,
modification, waiver or consent is sought.
3. Severability. The provisions of this Settlement Agreement are severable, and if
any part of it is found to be unenforceable, the other paragraphs shall remain in full force and
effect. This Settlement Agreement shall survive the termination of any arrangements contained
herein.
4. Multiple.Originals. This Settlement Agreement may be executed in any number
of multiple originals by different Parties hereto, each of which shall be deemed to be an original
and all of which when taken together shall constitute one or more of the same instruments.
5. Further Documents. Each party to this Agreement agrees to execute and to
deliver such additional documents and instruments and to perform such additional acts, as may
be necessary to effectuate, consummate or perform any of the terms, provisions or conditions of
this Agreement.
6. Governmental Immunity. Nothing in this Settlement Agreement shall be deemed
Page 5 of 7
to waive, modify or amend any legal defense available at law or in equity to either of the Parties
nor to create any legal rights or claim on behalf of any third party. The City does not waive,
modify, or alter to any extent whatsoever the availability of the defense of governmental
immunity under the laws of the State of Texas and of the United States.
7. Governing Law and Venue. This Settlement Agreement shall be construed and
interpreted in accordance with and governed by the laws of the State of Texas, without regard to
choice of law principles. Venue shall be in Williamson County, Texas.
8. Headings. The headings contained in this Settlement Agreement are merely for
convenience of reference and shall not under any circumstances affect the meaning or
interpretation of this Settlement Agreement.
9. THIS WRITTEN SETTLEMENT AGREEMENT REPRESENTS THE
FINAL AGREEMENT AMONG THE PARTIES AND MAY NOT BE CONTRADICTED
BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR SUBSEQUENT ORAL
AGREEMENTS AMONG THE PARTIES.
IN WITNESS WHEREOF, the parties hereto have caused this Settlement Agreement to
be executed as of the day and year first above written.
FILLIP CONRUCTION COMPANY,INC.
Title: President
CITY OF ROUND ROCK
By: Nyle Maxwell
Title: Mayor
ATTEST:
By:
Christine R. Martinez
Title: City Secretary
Page 6 of 7
APPROVED AS TO FORM:
By:
Stephan L. Sheets
Title: City Attorney
STATE OF TEXAS §
COUNTY OF WILLIAMSON §
SUBSCRIBED AND SWORN TO before me by ,
President of FILLIP CONSTRUCTION COMPANY, Inc., on this day of April, 2004.
Notary Public, State of Texas
My Commission Expires:
STATE OF TEXAS §
COUNTY OF WILLIAMSON §
SUBSCRIBED AND SWORN TO before me by Nyle Maxwell, Mayor of the City of
Round Rock, on this day of April, 2004.
Notary Public, State of Texas
My Commission Expires:
Page 7 of 7
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Gattis School Rd Turn Lanes
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From High Country Blvd to Red Bud Lane I
DATE: May 7, 2004
SUBJECT: City Council Meeting - May 13, 2004
ITEM: 13.H.1. Consider a resolution authorizing the Mayor to execute a
Settlement Agreement and Release with Fillip Construction
Company, Inc. for the Gattis School Roadway Project from
High Country Boulevard to Red Bud Lane.
Department: Transportation Services
Staff Person: Tom Martin, Director of Transportation Services
Justification: This settlement agreement will compensate Fillip Construction
Company for delays occurring to the initial start date, for the
Gattis School Roadway widening from High Country to Red Bud
Lane.
Funding:
Cost: $18,704.00
Source of funds: Capital Project Funds (2001 GO Bond)
Outside Resources: Fillip Construction Company, Inc.
Background Information: The Gattis School Roadway Project was delayed due
to a waterline tie-in under the pavement on Gattis
School Road. To prevent the destruction of newly
constructed roadway, the project was delayed until
such utility adjustments were completed.
Public Comment: N/A
EXECUTED
DOCUMENT
FOLLOWS
SETTLEMENT AGREEMENT AND RELEASE
mAy CRO,
This SETTLEMENT AG ENT and RELEASE (the "Settlement Agreement") is
entered into this 13 day of , 2004, by and between City of Round Rock, a home-rule
municipal corporation ("CORR"), and Fillip Construction Company, Inc., a Texas corporation
("FILLIP"), hereinafter collectively referred to as ("Parties").
WITNESSETH:
WHEREAS, on or about March 10, 2003, the Parties entered an Agreement (the
"Agreement") wherein FILLIP agreed to commence and complete the construction of certain
improvements described as the construction of turn lanes on Gattis School Road from High
Country Boulevard to Red Bud (the "Project");
WHEREAS, the terms of the Invitation for Bid and the responsive Proposal from FILLIP
required that the Project be completed within 90 calendar days after the date of the written
Notice-to-Proceed (the "Bid Completion Term") at a cost of One Hundred Eighty-Nine
Thousand Three Hundred Eighty-Five and 67/100 Dollars ($189,385.67) (the "Agreement
Price");
WHEREAS, the terms of the Agreement actually signed by the Parties require that the
Project be completed within forty-five (45) calendar days after the date of the written Notice-to-
Proceed (the "Agreement Completion Term");
WHEREAS, on or about October 20, 2003, a written Notice-to-Proceed was issued by
the CORR;
WHEREAS, a final walk-through has been conducted by the Parties;
WHEREAS, the Contract Period was exceeded by One Hundred Eighty-Six (186) days
through no fault of FILLIP ("Delay Period");
WHEREAS, the Delay Period has increased the cost of the Project to Two Hundred
Eight Thousand Eighty-Nine and 67/100 Dollars, a difference of Eighteen Thousand Seven
Hundred Four Dollars ($18,704.00) (the "Delay Cost-);
WHEREAS, FILLIP has made a claim to CORR for the Delay Cost incurred and
associated with the Delay Period ("Delay Claim"); and
WHEREAS, the Parties have determined that it is in their respective interests to
terminate all disputes and controversies existing between them relating to the Agreement and the
Parties have negotiated and agreed to a settlement of all disputes and controversies between them
relating to the Agreement;
Page 1 of 7
P-04-05-13-13111
NOW THEREFORE, in consideration of the mutual promises and covenants contained
herein, the adequacy and sufficiency of which are hereby acknowledged, and with the intent to
be legally bound hereby, the parties hereto agree as follows:
I. AGREEMENTS
1. In consideration of the total sum of Eighteen Thousand Seven Hundred Four and
No/100 Dollars ($18,704.00) paid by CORR to FILLIP, the receipt and sufficiency of which is
hereby acknowledged by FILLIP, and in consideration of the mutual agreements, conditions,
representations, warranties, recitals, covenants and statements of intention contained herein,
FILLIP hereby accepts the above-referenced payment in full settlement, compromise and release
of all claims as arising out of or in connection with the Agreement against CORR.
2. Each Party agrees that the actual term for completion of the Project was ninety
(90) days and reform the Agreement to reflect such term for completion.
J. Each Party agrees to be solely responsible for the payment of their respective
attorney's fees and all other expenses incurred on said Party's behalf as a result of or in
connection with the Settlement Agreement.
II. RELEASE BY CLAIMANTS
1. Definition. As used in this Settlement Agreement, the term "Claims" shall mean
and refer to any and all claims of any kind or character whatsoever in law or in equity, foreseen
or unforeseen, matured or unmatured, known or unknown, accrued or not accrued, including,
without limitation, claims for usury, breach of contract, libel, slander, failure to provide goods
and services, failure to act in a commercially reasonable manner, extra-contractual damages,
violations of the Texas Deceptive Trade Practices act, violations of the Texas Business and
Commerce Code, fraud, negligence, gross negligence, deceit, intentional infliction of emotional
distress, breach of any express or implied duty of good faith and fair dealing, or any other claim
or cause of action, whether arising in contract or tort. Under this definition, "Claims" includes,
BUT IS NOT LIMITED TO, any and all claims, demands, lawsuits, debts, dues, accounts,
bonds, covenants, contracts, agreements, actions, cross-actions, rights of recovery, judgments,
liabilities, obligations, losses, costs, expenses, remedies and causes of action of any nature,
whether in contract or in tort, whether based upon fraud or misrepresentation, breach of duty, or
common law, or arising or by virtue of any judicial decision, federal or state statute or regulation,
for past, present and future injuries, property or economic damage, any act or omission or claim
asserted or which could have been asserted in a cause of action filed in court, and for all other
losses and damages of any kind, including, BUT NOT LIMITED TO, the following: all actual
damages; all exemplary, punitive and statutory damages; all penalties of any kind, including but
not limited to any and all penalties for usurious interest paid, taken, received, reserved,
contracted for or demanded; damage to business reputation; lost profits or good will;
consequential damages; damages ensuing from loss of credit: and pre judgment and post-
judgment interest, costs and attorneys' fees.
Page 2 of 7
2. In consideration for the agreements of CORR, acting for and with the intention of
binding itself and its respective heirs, legal representatives, executors, administrators, successors,
assigns, receivers and trustees and all beneficiaries for whom CORR may be acting as trustee,
FILLIP hereby RELEASES, WAIVES, ACQUITS and FOREVER DISCHARGES CORR, and
its agents, servants, employees, officers, directors, shareholders, attorneys, successors, and
assigns, past and present, from any and all Claims (as defined above), which FILLIP now has,
ever had, or ever may have against CORR that arise out of the Agreement or the Delay Claim,
except for any breaches of warranties, representation or obligations expressly set forth in this
Settlement Agreement or that are required by or survive the completion of the Project.
3. In consideration for the agreements of FILLIP, acting for and with the intention of
binding itself and its respective heirs, legal representatives, executors, administrators, successors,
assigns, receivers and trustees and all beneficiaries for whom FILLIP may be acting as trustee,
CORR hereby RELEASES, WAIVES, ACQUITS and FOREVER DISCHARGES FILLIP, and
its agents, servants, employees, officers, directors, shareholders, attorneys, successors, and
assigns, past and present, from any and all Claims (as defined above), which CORR now has,
ever had, or ever may have against FILLIP that arise out of the Agreement or the Delay Claim,
except for any breaches of warranties, representation or obligations expressly set forth in this
Settlement Agreement or that are required by or survive the completion of the Project.
4. The Parties acknowledge that this Settlement Agreement is being offered as a
settlement of a Claim and is not an admission by the Parties of liability or of any other matter not
expressly addressed in this Settlement Agreement. The Parties further agree that this matter is
being settled as purely a business decision without regard to the merits of any Claim.
M. REPRESENTATIONS AND WARRANTIES
1. CORR hereby stipulates, represents and warrants to FILLIP as follows:
(a) That CORR is the current legal and beneficial owner of all Claims
released hereby and has not assigned, pledged or contracted to assign or pledge any such
Claim to any other person or entity;
(b) That the terms and provisions of this Settlement Agreement are valid,
binding and enforceable as against CORR;
(c) That CORR is adequately represented by competent counsel and
accountants of its own choosing in connection with the execution and delivery of this
Settlement Agreement and in any and all matters relating thereto;
(d) That CORR is not under any form of legal disability or incapacity at the
time that they execute this Settlement Agreement;
(e) That CORR does not owe FILLIP any fiduciary duty and that CORR has
not relied upon FILLIP in a confidential or trust relationship in entering into this
Settlement Agreement.
(f) That in executing this Settlement Agreement, CORR has relied upon its
own judgment and the advice of its own attorneys, and further, that they have not been
Page 3 of 7
induced to sign or execute this Settlement Agreement by promises, agreements or
representations not expressly stated herein, and they have freely and willingly executed
this Settlement Agreement and expressly disclaim reliance upon any facts, promises,
undertakings or representations made by FILLIP or its attorneys other than the express
agreements, stipulations, representations and warranties contained herein;
(g) That the consent of CORR to this Settlement Agreement was not procured,
obtained or induced by improper conduct, undue influence or duress;
(h) That after investigation and consultation with its attorneys, CORR agrees
that this Settlement Agreement is fair, reasonable, and supported by good, valid, and
adequate consideration;
(i) That CORR has knowledge of all relevant and material information and
facts and has been fully informed, including by advice of counsel, concerning the
existence of potential claims against FILLIP, arising from or out of the Delay Claim, in
order to make an informed and considered decision to enter into this Settlement
Agreement, and that it is CORR's intention, based on the advice of counsel, and in
exchange for the consideration recited herein, to fully and finally release all Claims that
they have against FILLIP not otherwise reserved under this Settlement Agreement;
(j) That CORR is not in a significantly disparate bargaining position with
FILLIP;
(k) That CORR understands and agrees to the terms and conditions of this
Settlement Agreement; and
(1) That CORR understands and intends that FILLIP rely upon these
representations and warranties in entering into this Settlement Agreement.
2. FILLIP hereby stipulates, represents and warrants to CORR as follows:
(a) That FILLIP is the current legal and beneficial owner of all Claims
released hereby and has not assigned, pledged or contracted to assign or pledge any such
Claim to any other person or entity;
(b) That the terms and provisions of this Settlement Agreement are valid,
binding and enforceable as agsinst FILLIP;
(c) That FILLIP is adequately represented, or had an opportunity to be
represented, by competent counsel and accountants of its own choosing in connection
with the execution and delivery of this Settlement Agreement and in any and all matters
relating thereto;
(d) That FILLIP is not under any form of legal disability or incapacity at the
time that they execute this Settlement Agreement;
(e) That FILLIP does not owe CORR any fiduciary duty and that FILLIP has
not relied upon CORR in a confidential or trust relationship in entering into this
Settlement Agreement.
(f) That in executing this Settlement Agreement, FILLIP has relied upon its
own judgment and, where applicable, the advice of its own attorneys, and further, that
they have not been induced to sign or execute this Settlement Agreement by promises,
agreements or representations not expressly stated herein, and they have freely and
willingly executed this Settlement Agreement and expressly disclaim reliance upon any
Page 4 of 7
facts, promises, undertakings or representations made by CORR or its attorneys other
than the express agreements, stipulations, representations and warranties contained
herein;
(g) That the consent of FILLIP to this Settlement Agreement was not
procured, obtained or induced by improper conduct, undue influence or duress;
(h) That after investigation and consultation with its attorneys, or an
opportunity thereto, FILLIP agrees that this Settlement Agreement is fair, reasonable, and
supported by good, valid, and adequate consideration;
(i) That FILLIP has knowledge of all relevant and material information and
facts and has been fully informed, including by advice of counsel, concerning the
existence of potential Claims against CORR, arising from or out of the Delay Claim, in
order to make an informed and considered decision to enter into this Settlement
Agreement, and that it is FILLIP's intention, and in exchange for the consideration
recited herein, to fully and finally release all Claims that they have against CORR;
0) That FILLIP is not in a significantly disparate bargaining position with
CORR;
(k) That FILLIP understands and agrees to the terms and conditions of this
Settlement Agreement; and
(1) That FILLIP understands and intends that CORR rely upon these
representations and warranties in entering into this Settlement Agreement.
IV. MISCELLANEOUS PROVISIONS
1. Parties Bound. This Settlement Agreement shall be binding upon and shall inure
to the benefit of all the Parties and their respective heirs, directors, officers, shareholders,
executors, administrators, personal representatives, successors and assigns.
2. No Oral Modification. No amendment to, modification or waiver, or consent with
respect to, any provision of any of this Settlement Agreement shall be effective unless the same
shall be in writing and signed by the Party against whom enforcement of the amendment,
modification, waiver or consent is sought.
3. Severability. The provisions of this Settlement Agreement are severable, and if
any part of it is found to be unenforceable, the other paragraphs shall remain in full force and
effect. This Settlement Agreement shall survive the termination of any arrangements contained
herein.
4. Multiple Originals. This Settlement Agreement may be executed in any number
of multiple originals by different Parties hereto, each of which shall be deemed to be an original
and all of which when taken together shall constitute one or more of the same instruments.
5. Further Documents. Each party to this Agreement agrees to execute and to
deliver such additional documents and instruments and to perform such additional acts, as may
be necessary to effectuate, consummate or perform any of the terms, provisions or conditions of
this Agreement.
6. Governmental Immunity. Nothing in this Settlement Agreement shall be deemed
Page 5 of 7
to waive, modify or amend any legal defense available at law or in equity to either of the Parties
nor to create any legal rights or claim on behalf of any third party. The City does not waive,
modify, or alter to any extent whatsoever the availability of the defense of governmental
immunity under the laws of the State of Texas and of the United States.
7. Governing Law and Venue. This Settlement Agreement shall be construed and
interpreted in accordance with and governed by the laws of the State of Texas, without regard to
choice of law principles. Venue shall be in Williamson County, Texas.
8. Headings. The headings contained in this Settlement Agreement are merely for
convenience of reference and shall not under any circumstances affect the meaning or
interpretation of this Settlement Agreement.
9. THIS WRITTEN SETTLEMENT AGREEMENT REPRESENTS THE
FINAL AGREEMENT AMONG THE PARTIES AND MAY NOT BE CONTRADICTED
BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR SUBSEQUENT ORAL
AGREEMENTS AMONG THE PARTIES.
IN WITNESS WHEREOF, the parties hereto have caused this Settlement Agreement to
be executed as of the day and year first above written.
FILLIP CONS UCTION COMPANY, INC.
By: g
Title: President
CITY OF ROUND ROC
yle axwell
Title: Mayor
ATTEST:
By: '
Christine R. Martinez
Title: City Secretary
Page 6 of 7
APPROV AS TO FO
By:
Ste han L. Sheets
Title: City Attorney
STATE OF TEXAS §
§
COUNTY OF WILLIAMSON §
SUBSCRIBED AND SWORN TO before me by r—f /lip
President of FILLIP CONSTRUCTION COMPANY, Inc., on this ay of il, 2004.
/VX a
���AN�{�tirfry,�
� N C.F(p l
v
• Notary Public, State of Texas
=?s •' oFt��;'
'ti •'••.�rrlREs.•• �.� My Commission Expires:
STATE OF TEXAS §
COUNTY OF WILLIAMSON §
SUBSCRIBED AND SWORN TO before me by Nyle Maxwell, Mayor of the City of
Round Rock, on this 3 day ofd, 2004.
rnA y
- - -
,W'% CHRISTINE R.MARTINEZ Notary Public, State of Texas
MY COMMISSION EXPIRES
=',S..... August 28,2005 r
My Commission Expires: E-C �-QJ
Page 7 of 7