HomeMy WebLinkAboutBPW-03-31-11-01 Martin Marietta Agreement/106th & Gray RdResolution NO. BPW - 03- 31 -11 -01
A RESOLUTION OF THE BOARD OF PUBLIC WORKS AND SAFETY
OF THE CITY OF CARMEL, INDIANA, APPROVING THE SETTLEMENT
AGREEMENT ENTERED INTO BY BOARD WITH AMERICAN AGGREGATES
CORPORATION D /B /A MARTIN MARIETTA AGGREGATES, AND AUTHORIZING
THE EXECUTION BY THE BOARD OF THE SETTLEMENT AGREEMENT AND
AUTHORIZING THE DIRECTOR OF CARMEL UTILITIES TO CONSUMMATE THE
SETTLEMENT AND ALL MATTERS TO BE CARRIED OUT UNDER THE TERMS
OF THE SETTLEMENT AGREEMENT
WHEREAS, the Board of Public Works and Safety of the City of Carmel, Indiana, on Behalf
of Carmel Utilities ( "City ") commenced an action to condemn a portion of certain property owned by
American Aggregates at the southeast corner of 106`h and Gray Road in Indianapolis, Indiana, which
action is currently pending and styled as Board of Public Works and Safety of the City of Carmel,
Indiana on behalf of Cannel Utilities vs. American Aggregates Corporation d /b /a Martin Marietta
Aggregates, Cause No. 29D01- 0610PL1055, in the superior Court of Hamilton County, Indiana (the
"Lawsuit ") and is set for Jury Trial on April 4, 2011; and
WHEREAS, in resolution of certain objections filed by American Aggregates in respect to
the claim of the right and power to condemn the property by the City, the parties entered into that
certain Agreement for Purchase and Sale (the "Purchase Agreement "), dated September 27, 2007,
with respect to reducing the land which was the subject of the proposed taking from 30 acres to 20
acres, and providing for the transfer of title to the surface portion of such 20 acre parcel and the
subsequent transfer of the subterranean portion, each of which is more particularly described therein
(the "20 -Acre Parcel "); and
WHEREAS, as part and parcel to the acquisition of the 20 -Acre Parcel, and in connection
with the "closing" of the purchase and sale thereof, the parties entered into that certain Co- Existence
Agreement dated September 27, 2007; and
WHEREAS, the parties closed the purchase and sale of the 20 -Acre Parcel on May 9, 2009,
and in connection therewith American Aggregates executed and delivered in favor of the City that
certain Limited Warranty Deed recorded May 2009, as Instrument No. 20090027537 in the office of
the Recorder of Hamilton County, Indiana, thereby conveying the 20 -Acre Parcel which is the
subject of the said Purchase Agreement and the Lawsuit; and
WHEREAS, the parties pursuant to the Purchase Agreement, contemplated resolving the
matter of damages due and payable by the city to American Aggregates in connection with the
acquisition of the 20 -Acre Parcel pursuant to the provisions of the Indiana Code 32 -24 -1 et seq. (the
"Act "), either by agreement or pursuant to a trial by jury in the Lawsuit; and
WHEREAS, the parties have reached an agreement as to the amount of damages and fair and
just compensation due and owing by the City to American Aggregates in connection with the
condemnation and acquisition of the 20 -Acre Parcel, together with other considerations, and are
proposing to enter into the Settlement Agreement attached to this Resolution as Exhibit A.
1574231
EXECUTION COPY
NOW, THEREFORE, BE IT RESOLVED AND AGREED by the Board of Public Works
and Safety of the City of Carmel, Indiana ( "BPW "), as follows:
1. That the BPW hereby approves the terms and conditions contained in the Settlement
Agreement with regard to the City's settling the Lawsuit and completing the acquisition of that
certain property owned by American Aggregates at the Southeast corner of 106`" Street and Gray
Road in Indianapolis.
2. That the presiding officer of the BPW and Safety or a designee on the BPW is authorized
and directed to execute, deliver and accept delivery of any and all documents required to close the
Settlement Agreement.
3. That the provisions of the Settlement Agreement call for the City to make designated
payments to American Aggregates by April 11, 2011; to negotiate an acceptable location for a well
site to be transferred to the City as part of the Settlement Agreement; and the negotiation of the
City's purchase from American Aggregates of an amount of excess stone or ground water from
American Aggregates. The BPW hereby authorizes and directs the Director of Carmel Utilities to
carry out all of these terns and conditions and provisions contained in the Settlement Agreement and
to consummate those transactions contemplated or otherwise required by the terms of the Settlement
Agreement. Furthermore the BPW hereby delegates the execution of all documents required for the
consummation of the well site and water purchase agreement contemplated by the terms of the
Settlement Agreement to be carried out by the Director of Carmel Utilities. Furthernore, legal
counsel for BPW in the Lawsuit is authorized to execute the Settlement Agreement as to its fore and
file a Stipulation of Dismissal with Prejudice in the Lawsuit as provided for in the Settlement
Agreement.
1574231 2
EXECUTION COPY
SO RESOLVED by the Board of Public Works and Safety of the City of Carmel, Indiana,
this day of March, 2011.
CITY OF CARMEL, INDIANA
BY ITS BOARD OF PUBLIC WORKS
AND SAFETY
_Ames Brainard, Presiding Officer
Date: 3�/(
Date:
urke, Member
3/i
Lori talsofi, Member
Date: 3/ 3' i it
ATTEST:
Diana L. Cordray, IAMC Clerk- Treasurer
1574231 3
STATE OF INDIANA
COUNTY 0
)
)
SS:
EXECUTION
COPY
Before me, a Notary Public in and for said County and State, personally appeared James
Brainard, Mary Ann Burke, and Lori Watson, by me known to be the Members of the City of
Carmel Board of Public Works and Safety, and Diana L. Cordray, Clerk- Treasure of the City of
Carmel, who acknowledged the execution of the foregoing "Agreement" on behalf of the City of
Carmel, Indiana.
Witness my hand and Notarial Seal this
My Com ission Expires:
30 c)e/
Prepared by:
Randolph L. Seger
BINGHAM MCHALE LLP
2700 Market Tower
10 West Market Street
Indianapolis, Indiana 46204
1574231 4
day of la_r-
_/ 4k.1 /
IOTARY PUBLIC
OH.
fik
Printed Name
My County of Residence:
Date:
EXECUTION COPY
EXHIBIT A
SETTLEMENT AGREEMENT
1574231 5
EXECUTION COPY
SETTLEMENT AGREEMENT
THIS SETTLEMENT AGREEMENT (this "Agreement "), made and entered into,
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binding and effective as of this 3/1---
day of March, 2011 (the "Effective Date "), by and
between the BOARD OF PUBLIC WORKS AND SAFETY OF THE CITY OF CARMEL,
INDIANA, ON BEHALF OF CARMEL UTILITIES (hereinafter referred to as the "City "), and
AMERICAN AGGREGATES CORPORATION d/b /a MARTIN MARIETTA AGGREGATES
(hereinafter referred to as "American Aggregates "),
WITNESSES THAT:
WHEREAS, the City commenced an action to condemn a portion of certain property
owned by American Aggregates at the southeast corner of 106th and Gray Road in Indianapolis,
Indiana, which action is currently pending and styled as Board of Public Works and Safety of the
City of Carmel, Indiana, on behalf of Carmel Utilities vs. American Aggregates Corporation
d/b /a Martin Marietta Aggregates, Cause No. 29D01- 0610PL1055, in the Superior Court of
Hamilton County, Indiana (the "Lawsuit "); and
WHEREAS, in resolution of certain objections filed by American Aggregates in respect
to the claim of the right and power to condemn the property by the City, the parties entered into
that certain Agreement for Purchase and Sale (the "Purchase Agreement "), dated September 27,
2007, with respect to reducing the land which was the subject of the proposed taking from 30
acres to 20 acres, and providing for the transfer of title to the surface portion of such 20 acre
parcel and the subsequent transfer of the subterranean portion, each of which is more particularly
described therein (the "20 -Acre Parcel "); and
WHEREAS, as part and parcel to the acquisition of the 20 -Acre Parcel, and in connection
with the "closing" of the purchase and sale thereof, the parties entered into that certain Co-
Existence Agreement dated September 27, 2007; and
WHEREAS, the parties closed the purchase and sale of the 20 -Acre Parcel on May 9,
2009, and in connection therewith American Aggregates executed and delivered in favor of the
City that certain Limited Warranty Deed recorded May 12, 2009, as Instrument No. 2009027537
in the office of the Recorder of Hamilton County, Indiana, thereby conveying the 20 -Acre Parcel
which is the subject of the said Purchase Agreement and the Lawsuit; and
WHEREAS, the parties, pursuant to the Purchase Agreement, contemplated resolving the
matter of damages due and payable by the City to American Aggregates in connection with the
acquisition of the 20 -Acre Parcel pursuant to the provisions of Indiana Code 32 -24 -1 et seq. (the
"Act "), either by agreement or pursuant to a trial by jury in the Lawsuit; and
WHEREAS, the parties have reached an agreement as to the amount of damages and fair
and just compensation due and owing by the City to American Aggregates in connection with the
condemnation and acquisition of the 20 -Acre Parcel, together with other considerations, and
enter into this Agreement for purposes of documenting such settlement and agreement.
NOW, THEREFORE, in consideration of the foregoing premises, and other good and
valuable consideration, the receipt and sufficiency of which is hereby acknowledged, and in
further consideration of the mutual promises and covenants hereinafter contained, the City and
American Aggregates hereby agree as follows:
1. The foregoing recitals are incorporated herein by reference as if fully restated
herein.
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2. The City hereby agrees to pay to American Aggregates by April 11, 2011, Two
Million Five Hundred Thousand Dollars ($2,500,000.00), less the earnest money deposit of Six
Hundred Forty Thousand Dollars ($640,000.00) made on or about September 27, 2007, pursuant
to the terms of the Purchase Agreement, for a net amount due and payable on or before April 11,
2011, One Million Eight Hundred Sixty Thousand Dollars ($1,860,000.00) (the "Settlement
Proceeds "), as damages and just compensation pursuant to the Act in consideration of its
acquisition of the 20 -Acre Parcel pursuant to the Purchase Agreement and in consideration of the
Well Site provisions set out in Paragraph 3 hereof and the water purchase provisions in
Paragraph 4 hereof
3. American Aggregates (or an affiliate thereof) owns certain unimproved real estate
located in and around the 20 -Acre Parcel on which lands the City seeks to locate a well (the
"Well Area "). Subject to receipt by American Aggregates of the payment described in paragraph
2, American Aggregates agrees to convey to the City a parcel of real estate with a radius of 100
feet of the actual well sited by the parties to allow the City to place a well in a mutually
acceptable location (the "Well Site ") in close proximity to or adjacent to a public right -of -way on
the Well Area that will meet all-regulatory requirements for a public water well and which will
be economic for the City to develop for purposes of extracting water, and to allow the City an
easement for an ingress and egress and for an underground pipe from which the City may access
such Well Site for purposes of transporting water for the City's public water utility system. The
exact location of the Well Site and the customary terms of the easement shall be subject to
mutual agreement of the parties, but in all events located in a location on the Well Area and
established in a manner so as to permit American Aggregates (or any affiliate thereof) to extract
all minerals from the Well Area (except within a radius of 100 feet of the actual well sited by the
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parties). The parties shall decide on the location of the Well Site and easement by negotiating in
good faith. The City shall locate the actual well in the center of the Well Site so that the City
maintains the radius of 100 feet. The City shall be responsible for obtaining all necessary local,
state and federal licenses and permits related thereto, and for otherwise complying with other
requirements necessary or convenient for the establishment of any such well. Within forty -five
(45) days after written agreement on the terms of the Well Site and easement referred to above,
American Aggregates shall execute a deed and the parties shall execute an easement in fawns
reasonably required in order to convey the Well Site parcel and to establish the right of the City
to access the same via an appropriate piping system. Such deed and easement shall contain terms
and conditions consistent with those of the Co- Existence Agreement to the extent applicable. The
Settlement Proceeds payable hereunder include compensation for the well site and the easement
contemplated by this Paragraph 3. In addition, the easement to be granted pursuant to this
Paragraph 3 shall provide that the City shall release, indemnify and defend American Aggregates
with respect to any and all claims arising out of the installation, operation, maintenance and
repair of the City facilities which are installed in the Well Site and in the easement for purposes
of transporting water from the Well Site to the right -of -way.
4. As per Paragraph 5 of the Co- Existence Agreement, the parties shall negotiate in
good faith for the purchase from American Aggregates by the City and sale by American
Aggregates of an amount of excess storm water or ground water that American Aggregates
would otherwise discharge into Blue Woods Creek as a part of its operation of its North Indy
plant situated south of the 20 -Acre Parcel and north of East 96th Street. The determination of the
existence of any excess water shall be made in American Aggregates sole and complete
discretion.
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5. The parties shall file in the Lawsuit a Stipulation of Dismissal With Prejudice in a
mutually acceptable form within ten (10) business days following the receipt by American
Aggregates of the Settlement Proceeds described in Paragraph 2 above.
6. It is specifically understood and agreed that the above stated Settlement Proceeds
are being made and accepted in full accord and satisfaction of and in compromise of, disputed
alleged claims and /or causes of action described in the Lawsuit, and for the purpose of
tenninating such disputes and avoiding further litigation between any of the said parties.
Nothing contained herein shall be deemed a waiver or limitation on the part of American
Aggregates or any of its parents, subsidiaries or affiliates, successors or assigns ( "American
Aggregates Affiliates ") of any theory or claim for compensation, if any, that may exist:
a. for any property taken in the future by the City (or any other governmental
agency) for purposes of extracting water from such property, and the
American Aggregates Affiliates expressly reserve whatever right they may
have, if any, to claim compensation for the value of such water in any
future condemnation or eminent domain proceeding; or
b. if the City (or any other governmental agency) changes regulations or the
enforcement thereof applicable to the Well Site and such regulations or
enforcement adversely impact operations by American Aggregates
Affiliates.
7. The City and American Aggregates hereby specifically acknowledge and agree
that they are entering into this Agreement upon the specific advice and with the consent of their
attorneys of record in the Lawsuit, and not based upon representations or agreements other than
those set forth herein and in those agreements between the parties that are referred to herein.
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8. Each party hereto shall bear its own legal fees and costs incurred in connection
with the matters referred to herein, and neither shall be responsible for any fee or cost incurred
by the other.
9. This Agreement shall be governed in accordance with the laws of the State of
Indiana.
IN WITNESS WHEREOF, the City and American Aggregates, each by their duly
authorized agents and officers, have caused this Agreement to be executed as of the day, month
and year first above written.
CITY OF CARMEL, INDIANA AMERICAN AGGREGATES CORP
BY ITS BOARD OF PUBLIC WORKS d/b /a MARTIN MARIETTA
AND SAFETY i, AGGREGATES
,dd nes Brainard, Presiding Officer
Date:
Mary : urke, Member
Date: 3-3 1- `)
Lori : •n, Member
Date: 3/3 ►
ATTEST:
A 7
Diana L. Cordray, IAMC Clerk -Tre surer
/oad
6
By:
(Signatur
Its: Vice fi atAl- 5tJen
(Printed Name & Title)
Approved as to Form:
ICE MILL LLP
By:
s, Attorney for Defendant
Approved as to Form;
L. Sege Attorney for Plaintiff
STATE OF. INDIANA
COUNTY OF
SS:
Before me, a Notary Public in and for said County and State, personally appeared James
Brainard, Mary Aim Burke, and Lori Watson, by me known to be the Members of the City of
Carmel Board of Public Works and Safety, and Diana L. Cordray, Clerk - Treasure of the City of
Carmel, who acknowledged the execution of the foregoing "Agreement" on behalf of the City of
Cannel, Indiana.
Witness my hand and Notarial Seal this
My Commission Expires:
day of ,2011.
7
NOTARY PUBLIC
n GL i'Cti Cn r ,SCS
Printed Name
My County of Residence:
Date:
,3/31/7