HomeMy WebLinkAbout18-124 - LG Hotels dba Travelodge SeaTac - Public Safety Plan Settlement Agreement18-124
Council Approval 6/18/18
SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS
L.G. HOTELS LLC, doing business as TRAVELODGE SEATAC ("Travelodge") and the CITY
OF TUKWILA ("City"), a Washington municipal corporation ("the City"), collectively ("the
Parties"), hereby enter into this Settlement Agreement, which shall become effective upon mutual
execution by the Parties.
I. RECITALS
A. On November 6, 2017, the Tukwila City Council adopted Ordinance No. 2554, authorizing the
City to acquire all property rights necessary to complete its Public Safety Plan Projects (the
"Projects") through negotiation and/or the use of eminent domain, if necessary.
B. On December 8, 2017, the City filed a Petition in Eminent Domain ("Petition") to acquire
property located at 14845 Tukwila International Boulevard, Tukwila, Washington, also known as
King County Parcel No. 004100-0335 (the "Property").
C. Travelodge is a lessee on the Property and was served with the City's Petition on December 22,
2017. Travelodge appeared on January 5, 2018.
D. The City contends that: 1) the City is not required to pay Travelodge relocation assistance
pursuant to state and federal law; and 2) Ordinances 2550 and 2554 are valid. Travelodge
contends that: 1) Ordinances 2550 and 2554 are invalid; and 2) they are entitled to relocation
assistance pursuant to state and federal law regardless of the validity of Ordinances 2550 and
2554.
E. The Parties desire to resolve any and all issues related to the City's acquisition of the Property
by entering into this Agreement. The Parties intend that this Agreement will fully resolve these
matters and Travelodge waives any and all rights to bring litigation related to the City's acquisition
of the Property, the Projects, or relocation expenses.
NOW, THEREFORE, for and in consideration of obligations and exchange of promises set forth
herein, the Parties agree as follows:
II. AGREEMENT
1. City Payment. The City shall pay Travelodge the sum of Sixty Thousand Dollars and
No/100 ($60,000.00), which payment shall be made to Travelodge as follows: (1) payment in the
amount of $30,000 to be paid within thirty (30) days of mutual execution of this Agreement; and
(2) payment of the remaining balance of $30,000 to be paid within thirty (30) days after Travelodge
has vacated the Property and such vacation has been verified by the City, provided that all other
settlement conditions have also been met and Travelodge has provided a completed W-9 to the
City. The second payment shall not be made if Travelodge has not vacated the Property by March
31, 2019, as required by Section 2 herein. Payments will be made by check made payable to
Travelodge and mailed to: 14845 Tukwila International Boulevard, Tukwila, Washington 98168.
SETTLEMENT AGREEMENT - 1
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In addition, the City shall make payment in the amount of $5,000 to the Inslee Best law firm for
payment towards Travelodge's attorney fees. That payment shall be mailed to Inslee Best, care of
Kinnon Williams, Post Office Box 90016, Bellevue, Washington 98009-9016, within thirty (30)
days of mutual execution of this Agreement, provided Inslee Best has provided a completed W-9
to the City.
2. Possession and Personal Property. Travelodge must cease operations and vacate the
Property on or before March 31, 2019. Should Travelodge fail to do so, the second payment to be
made by the City to Travelodge under Section 1 herein shall not be made and the City, in its sole
discretion, may seek repayment of the initial payment made to Travelodge under Section 1 of this
Agreement. The City will consider any personal property left behind on the premises by
Travelodge to be abandoned property of no value. Travelodge consents to having any such
personal property, garbage, or waste disposed of by the City.
3. Permit Fee Credit. Should Travelodge decide to relocate its business operations to
another location within the City of Tukwila, Travelodge shall be entitled to a permit fee credit of
up to $2,500 to be applied to any permit fees required by the City of Tukwila related to tenant
improvements made by Travelodge at such new location. This credit can be applied to any land
use, building permit, mechanical permit, electrical permit, plumbing permit, sign permit, or public
works permit. This credit is non -transferable, has no cash value, and shall expire on January 1,
2021.
4. Participation in Condemnation Proceedings and Release. In exchange for the payments
and permit fee credit provided to Travelodge under this Agreement, Travelodge knowingly and
voluntarily agrees to release and forever discharge the City (including its past and present officers,
officials, directors, shareholders, employees and successors in interest) from all claims, demands,
liabilities, and causes of action of any nature related in any way to the City's acquisition of the
Property, the Project, relocation assistance under chapter 8.26 RCW or federal law, or arising from
Travelodge's current lease agreement with Jing Wei, LLC, whether the bases of such claims,
dema6ds, liabilities, ancUor causes of action are currently known or unknown and whether such
claims, demands, liabilities, and/or causes of action have accrued in the past or will first accrue in
the future. Travelodge agrees not to contest public use and necessity of the Project or to otherwise
interfere, directly or indirectly, with the Project (including but not limited to appeal of any Project
permits), and agrees to grant the City immediate possession and use upon the City's request for
such. Such possession and use agreement shall allow the City reasonable access to the Property
for the purposes of Project planning, studies, environmental assessments, survey work, and the
like.
5. Subleases and Assignment. Travelodge affirms and acknowledges that is has no
subleases in the tenant space it currently occupies. Travelodge agrees not to enter into any
subleases, and Travelodge shall not assign or subcontract any portion of the services contemplated
by this Agreement without the express written consent of the City. Travelodge will ensure that
the Property is vacant on or before March 31, 2019.
SETTLEMENT AGREEMENT -2
6. No Admissions. This Agreement does not constitute an admission of liability by the
Parties. In the event of future inquiries, the Parties agree not to disparage any other with respect
to the subject matter of this Agreement. This paragraph does not preclude or otherwise impact the
City's obligation to comply with the Public Records Act, nor does it preclude either party from
seeking to enforce the terms of this Agreement. In any dispute resolution proceeding between the
Parties in connection with this Agreement, the prevailing party will be entitled to recover its
reasonable attorneys' fees and costs from the other party.
7. Authority. The signatories to this Agreement represent that they have the full right and
authority to enter into this Agreement on behalf of the Parties and the full right and authority to
fully bind the Parties to the terms and obligations of this Agreement. Travelodge Further
represents affirms and acknowledges that there are no subleases to the tenant space it currently
occupies, and Travelodge expressly agrees not to enter into any such subleases.
8. Counterparts. This Agreement may be executed in duplicate counterparts, in which case
each executed counterpart shall be deemed to be an original and all counterparts together shall
constitute one and the same instrument. Signed versions of this Agreement transmitted by
facsimile copy or electronic mail shall be the equivalent of original signatures on original versions.
9. Entire Agreement; Venue; Attorneys' Fees. This Agreement contains all of the
agreements of the Parties with respect to any matter covered or mentioned in this Agreement. No
provision of this Agreement may be amended or modified except by written agreement signed by
the Parties. This Agreement shall be governed by and construed in accordance with the laws of the
State of Washington. In the event any suit, arbitration, or other proceeding is instituted to enforce
any term of this Agreement, the parties specifically understand and agree that venue shall be
properly laid in King County, Washington. The prevailing party in any such action shall be entitled
to its attorneys' fees and costs of suit.
10. Knowing and Voluntary Execution. The Parties hereto enter into this Agreement
knowingly, willingly, voluntarily, freely, and without any coercion. The parties have been advised
to consult with an attorney concerning this Agreement and have had adequate opportunity to seek
the advice of legal counsel in connection with this Agreement.
AGREED TO BY:
THE CITY OF TUKWILA
a Washington munici orporation
By:
Name:
Title:
8-ZI- 16
SE 1 1 LEMENT AGREEMENT - 3
LG HOTELS LLC
DBA TRAVELODGE SEATAC
Parwinder Dhanda
,2Z)Aancec,
Satwinder Dhanda
Approved as to form:
Rachel B. Turpin
City Attorney
NOTARY ACKNOWLEDGEMENT
STATE OF WASH TON )
) ss.
COUNTY OF KING
I certify that I know or ve satisfactory evidence that Parwinder Dhanda and Satwinder
Dhanda signed this instrument . on oath, stated that they were authorized to execute the
instrument and acknowledged it a the Managing Members of LG HOTELS LLC dba
TRAVELODGE SEATAC, to be the fre nd voluntary act of such party for the uses and purposes
mentioned in the instrument.
DATED this day of , 2018.
(SEAL)
Printed Name:
Notary Public in and for he State of Washington.
My commission expires
SE 1 1 LEMENT AGREEMENT - 4