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McAninch Corp vs CityBarry A. Lindahl, Esq. Corporation Counsel 196 Dubuque Building 700 Locust Street Dubuque, Iowa 52001-6824 (319) 5834113 (319) 583-1040 FAX E-moji: bojesq~mwd.net May 30, 2001 Mayor Pro Temp Joseph Robbins and City Council Members 50 West 13th Street Dubuque, IA 52001 RE: McAninch Corporation v. City of Dubuque Dear Mayor and Council Members: Les Reddick and I are pleased to report to you that we have reached an agreement with the McAninch Corporation to resolve the pending lawsuit against the City of Dubuque within the guidelines established by the City Council. This lawsuit arises out of the contract between McAninch Corporation and the City of Dubuque for excavating and grading at the westside industrial park. McAninch Corporation claimed that as a result of delays by the City in obtaining certain permits from the Department of Natural Resources for re-chauneling waterways at the project site, McAninch sustained damages for additional excavation work as well as additional costs for remaining on the site beyond the time they had intended to complete the project. The City's position in the lawsuit was that the delays were the result of a failure on the part of the City's consulting engineers, Kirkham & Michael, in advising the City as to when and how to obtain the necessary permits. The original claim by McAninch was in excess of $500,000. Through the process of negotiation and mediation, McAninch agreed to accept the sum of $195,000 for a resolution of its claims. The City wilt contribute $140,000 toward that settlement mount and the Iowa Communities Assurance Pool will also contribute $20~000 on behalf of the City. The City will also be required to reimburse the Iowa Communities Assurance Pool for the deductible, which is an amount less than $10,000. The City's total contribution to the settlement therefore is less than $150,000, which is consistent with direction provided by the City Council: Kirkham & Michael, the City's engineering consulting firm, will contribute $35,000 to the settlement. All of the parties will release each other from any other claims arising out of this project. Service People Integrity Responsibility Innovation Teamwork BAL/jm Attachment Cc: Very sincerely, Michael Van Milligen, City Manager Michael Koch, Public Works Director/City Engineer Les Reddick, Esq. Frank Miller, Public Entity Risk Services Brian J. Kane Gary K- Norby Les ¥. Reddick* D. Flktt Drake*'~ Brad J. Pieying Todd L. Stevenson* Louis P. Pfeiter MaryBeth Pfeiler Salmon Mary A. Cherba KANE, NORBY & REDDICK, P.C. ATTOKNEY$ 2100 ASBUI~Y ROAD, SIDI'I'~ 2 DUBUQLFE, LA. 52001-3069 All admitted in Iowa ~Also admitted in Illinois ~Also admitted in Wiscortsi~ Phoae: (563) 582-7980 Facs'maile: (563) 582-5312 E-mail: lmrpc~mdeod~sa.net May 24, 2001 Mr. Barry A. Lindahl Corporation 196 Dubuque 700 Locust Stre~ Dubuque, IOwa 52001-6824 RE: MCANINCH V. CITY OF DUBUQUE Dear Barry: This will confirm settlement of the McAninch for a total of $195,000: The City.of Dubuque will pay $140,000, Iowa. Communities Assurance Pool will pay $20,000 and Kirkham, Michael will pay $35,000. In exchange, we will receive a dismissal with prejudice of the pending, tawsuit~ dismiss our third-parmy lawsuit agamns5 Kirkham, Mich~I and'e~change mutual releases. Would you please order the draft and forward it to my attention. Best personal .regards. Very truly yours, KANE~ NORBY & REDDICK, P.C. Les V. Reddick LVR/bmc