Johnson Settlement Agreement (Added on 1/7/22)

City of Glendale — Regular Meeting (2022-01-11)

View PDF Item 18 Meeting page

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SETTLEMENT AGREEMENT 
 
This Settlement Agreement (the “Agreement”) is made and entered into this 7th day of 
January, 2022, by and between the Rudolph Johnson Family L.L.C. (“Johnson”) and the City of 
Glendale, an Arizona municipal corporation (“Glendale”).  This Agreement will become 
effective on the date on which the Glendale City Council approves it pursuant to Paragraph 21 
below (the “Effective Date”).  Johnson and Glendale are collectively referred to herein as the 
“Parties,” or individually as a “Party.” 
 
RECITALS 
 
WHEREAS, Johnson owns real property located  at the southeast corner of North 99th 
Avenue and Olive Avenue in Maricopa County, Arizona, identified in the records of the 
Maricopa County Assessor as APNs 142-55-006D and 142-55-006C; 
 
WHEREAS, this Agreement concerns the northern portion of the property identified as 
APN 142-55-006D and all of the property identified as APN 142-55-006C, as generally depicted 
in Exhibit A, except for any portion thereof lying in the North 99th Avenue Right-of-Way 
(together, the “Johnson Property”); 
 
WHEREAS, Johnson’s predecessors-in-interest leased approximately 16 acres of the 
Johnson Property to Glendale in 1968 to operate and maintain a municipal landfill; 
 
WHEREAS, Glendale operated a municipal landfill on the Johnson Property until 
approximately December 1970, and then closed, graded, and returned possession of the leased 
land to Johnson’s predecessors-in-interest; 
 
WHEREAS, Johnson filed a lawsuit in the United States District Court for the District of 
Arizona against Glendale, Civil Action No. CV-19-05905-PHX-SRB (the “Lawsuit”), asserting 
claims against Glendale for breach of contract, negligence, nuisance, and claims under the 
Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) all 
relating to Glendale’s former operation of the landfill on the Johnson Property; 
 
WHEREAS, without admission of liability, the Parties wish to settle and compromise all 
of their disputes, differences, and claims, whether known or unknown, asserted or unasserted, 
which are in any way related to the Lawsuit; and 
 
NOW, THEREFORE, in consideration of the mutual promises, undertakings, and 
valuable consideration set forth below, the sufficiency of which is acknowledged by the Parties, 
the Parties agree as follows: 
 
AGREEMENT 
 
1. 
Intent and Purpose of the Agreement.  Without any admission of liability and 
expressly denying same, it is the intent of the Parties and the purpose of this Agreement to fully 
and finally settle and resolve all disputes between the Parties relating in any way to the Johnson 
4896716.3

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Property, including the Lawsuit; to provide for payment as stated below; and to provide for a full 
and complete release.   
 
2. 
Transfer of Title.  
 
a. Johnson agrees to convey and assign the Johnson Property to Glendale on the 
terms and subject to the conditions of this Agreement. Prior to the Property 
Closing (defined below), the southern boundary line of the Johnson Property and 
the location of the four vapor-monitoring wells located on the Johnson Property 
(the “Vapor Monitoring Wells”) and the three (3) groundwater monitoring wells 
(the “Groundwater Monitoring Well”) shall be mutually agreed to by the Parties 
and set forth on the Survey (defined below). At the Property Closing, Johnson 
shall convey to Glendale all of its right, title, and interest in and to the Vapor 
Monitoring Wells, the Groundwater Monitoring Wells and all associated 
equipment. The Parties agree to use commercially reasonable efforts to cause the 
consummation of the conveyance and assignment of the Johnson Property from 
Johnson to Glendale (the “Property Closing”) to occur within sixty (60) days after 
the Effective Date, or as soon thereafter as commercially reasonable. At the 
Property Closing, Johnson shall (i) convey title to the Johnson Property to 
Glendale free and clear of any and all liens, encumbrances, or security interests, 
and (ii) give full, complete, and actual possession of the Johnson Property to 
Glendale, free and clear of all tenancies and other rights of occupancy in favor of 
any third parties. At the Property Closing, Johnson and Glendale shall enter into 
an Easement Agreement, in substantially the form attached hereto as Exhibit B 
(the “Easement Agreement”), pursuant to which, among other things, Glendale 
will convey to Johnson a non-exclusive easement for the sole purpose of the use, 
repair, and maintenance of the irrigation system located on the Johnson Property 
as of the date of the Property Closing (the “Ditch Easement”). Additionally, 
promptly following the Effective Date, Johnson shall use commercially 
reasonable efforts to cause the Maricopa County Tax Assessor to issue a single 
Assessor Tax Parcel Number for the Johnson Property. 
 
b. Promptly following the Effective Date, but in no event later than thirty (30) days 
thereafter (the “Title Commitment Delivery Deadline”), Johnson shall furnish to 
Glendale a current commitment (the “Title Commitment”) for an owner’s title 
insurance policy issued by a title company selected by Glendale (the “Title 
Company”), covering only the Johnson Property in an amount equal to the fair 
market value of the Johnson Property, as determined by Glendale in its sole 
discretion (the “Insured Amount”). Notwithstanding the forgoing, if, despite 
Johnson’s best efforts, it cannot obtain the Title Commitment on or before the 
Title Commitment Delivery Deadline, the Title Commitment Delivery Deadline 
shall be extended for one (1) additional period of thirty (30) days. At the Property 
Closing, Johnson, at its sole cost and expense, shall furnish to Glendale an ALTA 
Owner’s Title Insurance Policy, 6-17-06 (with deletion of the arbitration 
provisions and with extended coverage) issued by the Title Company in favor of 
Glendale and in the Insured Amount showing fee simple title in the Johnson

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Property to be vested in Glendale, free and clear of any and all liens, 
encumbrances, security interests, and tenancies and other rights of occupancy in 
favor of any third parties (other than the Ditch Easement), and subject only to 
those title matters which Glendale affirmatively agrees to accept, together with 
such endorsements, if any, as Glendale shall have requested from the Title 
Company at Glendale’s sole cost for such endorsements (the “Title Policy”). 
Promptly following the Effective Date, but in no event later than thirty (30) days 
thereafter (the “Survey Delivery Deadline”), Johnson will, at its own expense, 
obtain and deliver to Glendale a current ALTA survey of the Johnson Property, 
prepared by a surveyor or engineer licensed by the appropriate governmental 
authorities of the jurisdiction where the Johnson Property is located, which shall 
be in a form acceptable to Glendale and the Title Company (the “Survey”) and 
shall show the location of the southern boundary line of the Johnson Property and 
Ditch Easement. Notwithstanding the forgoing, if, despite Johnson’s best efforts, 
it cannot obtain the Survey on or before the Survey Delivery Deadline, the Survey 
Delivery Deadline shall be extended for one (1) additional period of thirty (30) 
days. At the Property Closing, Johnson shall execute, deliver, and perform, at 
Johnson’s expense, all documents, undertakings, and agreements required by the 
Title Company in order to issue the Title Policy, including, without limitation, an 
owner’s affidavit (or similar assurance) in the form required by the Title 
Company. 
 
3. 
Settlement Payment.  At the time of Property Closing in accordance with 
Paragraph 2 above, Glendale shall pay to Johnson via check made payable to “Rudolph Johnson 
Family L.L.C.” the sum of one hundred four thousand, five hundred ninety-six dollars and forty-
six cents ($104,596.46) (the “Settlement Payment”).   
 
4. 
Continued Involvement in VRP Program.  Within ten (10) business days of the 
Effective Date, Johnson shall withdraw its Voluntary Remediation Program (“VRP”) application, 
submitted to the Arizona Department of Environmental Quality (“ADEQ”) on behalf of Johnson 
on January 11, 2021 (the “Johnson Application”). Within ten (10) business days following the 
withdrawal of the Johnson Application, Glendale will submit a VRP application on its own 
behalf to address the soil and groundwater conditions identified at the Johnson Property, 
including but not limited to any PCE and TCE contamination in both soil and groundwater.  
Glendale agrees to remain in the VRP and upon achieving any remediation levels or controls 
required by ADEQ pursuant to A.R.S. § 49-175.B, Glendale shall submit a report to ADEQ 
pursuant to A.R.S. § 49-181(A), requesting that ADEQ issue a “no further action” determination 
for the Property pursuant to A.R.S. § 49-181(C).  The Parties acknowledge and understand that 
ADEQ may issue a conditional no further action determination pursuant to A.R.S. § 49-181(D) 
to the extent ongoing groundwater monitoring is necessary. 
 
5. 
Methane Monitoring and Mitigation.  Glendale will sample the four existing 
vapor monitoring wells on the Johnson Property on a quarterly basis for the first five (5) years 
and semiannually for an additional five (5) years.  However, monitoring will terminate after the 
first five (5) years and prior to the completion of these 10 (ten) years if and when the 
concentration of methane from each of the four vapor monitoring wells is below 10% of the

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lower explosive level (“LEL”) for four consecutive monitoring events.  If the results of any 
sampling event show methane exceeding 25% of the LEL, Glendale will undertake further 
sampling and analysis to determine whether such conditions require remediation, and if so, the 
appropriate mitigation measures in accordance with any applicable ADEQ requirements to 
prevent migration of methane from the Johnson Property to the adjacent property directly to the 
south of the Johnson Property (the “Southern Parcel”).   
 
6. 
Monitoring Data.  Glendale agrees to provide Johnson with the results of any 
sampling or submissions to ADEQ pursuant to Paragraphs 4 and 5, at the same time Glendale 
provides the submissions to ADEQ.   
 
7. 
Maintenance and Use of the Johnson Property.  Glendale agrees to perform 
routine maintenance on the Johnson Property, to keep it free of trash and debris, and not to allow 
any new use of the Johnson Property that would constitute a public nuisance, as defined by 
A.R.S. § 13-2917, or the installation of digital, commercial billboards.  Glendale agrees that it 
will limit signage placed on the Johnson Property to those stating “no trespassing,” “no 
loitering,” and/or “no dumping,” unless additional or different signage is required by law or in 
the public interest.   
 
8. 
Dismissal With Prejudice.  Within three (3) business days of the execution of 
this Agreement by both Parties, Johnson and Glendale shall file a joint notice of dismissal with 
prejudice of all claims asserted against Glendale in the Lawsuit in the form attached as Exhibit 
C.  The Parties further agree to take any and all additional steps that may be necessary, each at 
their own cost, to terminate fully and finally all proceedings in the Lawsuit. 
 
9. 
Representations and Warranties. 
 
a. Johnson represents and warrants that, as of the Effective Date, it is the sole lawful 
owner of the Johnson Property and that the Johnson Property is free and clear of 
any and all liens, encumbrances, security interests, tenancies, and other rights of 
occupancy in favor of any third parties. 
 
b. The Parties represent and warrant that, as of the Effective Date, they have the 
right and authority to agree to the matters set forth in this Agreement and, if 
applicable, that all necessary corporate actions have been taken to authorize 
execution of this Agreement, subject to approval by the Glendale City Council, as 
discussed in Paragraph 21 below. 
 
c. The Parties represent and warrant that, as of the Effective Date, they have not 
sold, assigned, transferred, conveyed, or otherwise disposed of any of the claims, 
demands, obligations, or causes of action referenced in this Agreement or released 
hereby. 
 
d. The Parties represent and warrant that, as of the Effective Date, they have 
produced in the Lawsuit all material information, including non-privileged

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documents within their possession, custody, or control relating to the historical 
uses of the Johnson Property. 
 
e. Except as revealed through discovery in the Lawsuit, Johnson represents and 
warrants that, as of the Effective Date, it is unaware of any actions or omissions 
undertaken by Johnson, its predecessors-in-interest, or any third party that could 
have created or exacerbated environmental conditions on the Johnson Property. 
 
f. The Parties agree that these representations and warranties shall survive execution 
and performance of this Agreement and dismissal of the Lawsuit for a period of 
four (4) years. 
 
10. 
Mutual Releases.  Except as to obligations and rights contained within this 
Agreement, the Parties agree to the following: 
 
a. Release by Johnson.  Johnson, on behalf of itself and its respective members, 
directors, officers, principals, agents, parents, subsidiaries, predecessors, 
successors, affiliates, attorneys, and assigns, hereby releases and forever 
discharges Glendale and its respective employees, elected officials, contractors, 
authorized representatives, insurers, principals, agents, predecessors, successors, 
affiliates, attorneys, and assigns, jointly and severally, from any and all claims, 
counterclaims, crossclaims, actions, damages, costs, liabilities, expenses, losses, 
demands, rights, and causes of action of any kind or nature, whether known or 
unknown, asserted or unasserted, disclosed or undisclosed, absolute or contingent, 
actual or consequential, which were brought or could have been brought in the 
Lawsuit.  Johnson hereby waives any right to assert that any claim released 
hereby has been, through oversight, error, unilateral mistake, or mutual mistake, 
unintentionally included in this Agreement.  Expressly excluded from this Release 
are any claims for breach of this Agreement, including any breach of the 
Representations and Warranties provided in Paragraph 9 above. 
 
b. Release by Glendale.  Glendale, on behalf of itself and its respective employees, 
elected officials, contractors, authorized representatives, insurers, principals, 
agents, predecessors, successors, affiliates, attorneys, and assigns, hereby releases 
and forever discharges Johnson and its respective members, directors, officers, 
principals, agents, parents, subsidiaries, predecessors, successors, affiliates, 
attorneys, and assigns, jointly and severally, from any and all claims, 
counterclaims, crossclaims, actions, damages, costs, liabilities, expenses, losses, 
demands, rights, and causes of action of any kind or nature, whether known or 
unknown, asserted or unasserted, disclosed or undisclosed, absolute or contingent, 
actual or consequential, which were brought or could have been brought in the 
Lawsuit.  Glendale hereby waives any right to assert that any claim released 
hereby has been, through oversight, error, unilateral mistake, or mutual mistake, 
unintentionally included in this Agreement.  Expressly excluded from this Release 
are any claims for breach of this Agreement, including any breach of the 
Representations and Warranties provided in Paragraph 9 above.

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11. 
Indemnification.  
 
a. To the fullest extent permitted by law, Glendale agrees to release, defend, 
indemnify, and hold harmless Johnson and its members, officers, 
employees, agents, successors, and assigns for, from, and against any and 
all claims, demands, actions, damages, judgments, settlements, personal 
injury (including sickness, disease, death, and bodily harm), property 
damage (including loss of use), infringement, governmental action, and all 
other losses and expenses, including attorneys’ fees and litigation expenses 
(each, a “Claim”) asserted by a third party, including any governmental 
authority, to the extent any such Claim arises out of the City’s: (1) use of 
the Johnson Property as a landfill and the presence of hazardous substances 
and methane on the Johnson Property as of the Effective Date, except to the 
extent that such hazardous substances and/or methane was placed on the 
Johnson Property by a third party unrelated to Glendale’s use of the 
Johnson Property as a landfill, or are migrating to the Johnson Property 
from an off-site source; and (2) ownership, operation, and maintenance of 
the Johnson Property, after the Effective Date, including Claims pertaining 
to the migration of hazardous substances or methane from the Johnson 
Property to the Southern Parcel, except to the extent that such hazardous 
substances and/or methane has migrated to the Johnson Property from an 
off-site source, or for any losses or expenses for which Johnson is obligated 
to indemnify Glendale pursuant to Section 6 of the Easement 
Agreement.  The foregoing indemnification obligation of Glendale shall 
survive any subsequent transfer of the Johnson Property by Glendale to a 
third party.   
 
b. In the event any Claim is asserted against Johnson, Johnson must notify 
Glendale within ten (10) business days of receiving written notice of such 
Claim.  Upon receipt of such notice, Glendale will assume Johnson’s 
defense with experienced counsel selected by Glendale, subject to the 
approval of Johnson, which shall not be unreasonably withheld, 
conditioned, or delayed. 
 
c. Glendale agrees that indemnifying Johnson for certain acts or omissions 
committed by Glendale’s employees or officials acting within the scope of 
their employment related to the Johnson Property does not violate Article 9, 
Section 7 of the Arizona Constitution (the “Gift Clause”) or Section 2-210 
of the Glendale City Code.   Glendale further agrees that it will not assert 
that the underlying act(s) associated with operating the landfill on the 
Johnson Property is or was a legislative or administrative function making 
Glendale absolutely immune from suit within the meaning of A.R.S. § 12-
820.01.

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d. This indemnification and hold harmless provision does not apply to: 
(1) Claims arising out of actions, errors, or omissions of Johnson or any 
third party undertaken after the Effective Date; and (2) Claims relating to 
any breach of the Representations and Warranties in Paragraph 9 above. 
 
12. 
Entire Agreement.  This Agreement supersedes all prior written and verbal 
promises and agreements between the Parties.  This Agreement constitutes the entire agreement 
between the Parties and may be amended, modified, or superseded only by a written agreement 
signed by all Parties, with appropriate authorization.   
 
13. 
Representation by Counsel and Non-Reliance on Representations of Other 
Parties.  The Parties acknowledge that they have been represented by competent and informed 
counsel in connection with the dispute underlying the Lawsuit and this Agreement, including in 
connection with the negotiations leading up to this Agreement and in connection with the 
drafting, execution, and effectuation of this Agreement.  Because all Parties participated in the 
negotiation and drafting of this Agreement, no Party shall be deemed its primary drafter for 
purposes of its construction or interpretation.  The Parties further acknowledge that they have 
relied on themselves and their own due diligence with regard to ascertaining the facts material to 
the execution of this Agreement, and that they, accordingly, have not relied in any manner on the 
other Party with respect to the provision or disclosure of any material information, other than 
representations contained in this Agreement.  Finally, the Parties acknowledge that this 
Agreement was entered into only after full and adequate representation by counsel, and that each 
Party is entering into this Agreement willingly and of its own informed and free will, fully 
cognizant of the effect and implications of doing so, and not acting under coercion or duress. 
 
14. 
Counterparts.  This Agreement may be validly executed in counterparts and all 
counterpart signatures taken together shall constitute the original Agreement.  Facsimile and 
electronic signatures shall have the same force and effect as original signatures. 
 
15. 
Severability.  If any provision of this Agreement is determined by a court or 
other tribunal of competent jurisdiction to be invalid, illegal, or unenforceable, such 
determination shall not affect or impair the validity, legality, and enforceability of the remaining 
provisions and all remaining provisions shall remain in full force and effect. 
  
16. 
Assumption of Risks.  Each Party hereto expressly accepts and assumes the risk 
that if facts with respect to matters covered by this Agreement are found hereafter to be other 
than or different from the facts now believed or assumed to be true, this Agreement shall 
nevertheless remain effective.   
 
17. 
Non-Waiver.  The failure to enforce any right arising under this Agreement on 
one or more occasions shall not operate as a waiver of that right under this Agreement on any 
other occasion. 
 
18. 
No Admission of Liability.  Each Party expressly denies that it has taken any 
improper action in violation of any federal, state, or local statute, law, regulation, or common law

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principle.  The Parties hereby agree that this Agreement shall not be admissible in any 
proceeding as evidence of any improper or unlawful conduct by any Party.   
 
19. 
Governing Law and Arbitration.  This Agreement shall be construed in 
accordance with the laws of the State of Arizona.  Any dispute regarding, relating to, or arising 
under this Agreement shall be submitted to binding arbitration administered by the American 
Arbitration Association in accordance with its Commercial Arbitration Rules.  The Parties shall 
share equally in the costs of such arbitration, and the arbitration award shall award reasonable 
attorney’s fees to the prevailing Party. In the event that the Parties are unable to effectuate the 
Property Closing and transfer of title as provided in Paragraph 2 above, the Parties agree to 
submit the claims currently pending in the Lawsuit and/or the dispute over the property transfer 
for resolution in binding arbitration pursuant to this provision.  
 
20. 
Notices.  All notices in connection with this Agreement shall be in writing and 
delivered as follows: 
 
To Rudolph Johnson Family L.L.C.: 
 
Rudolph Johnson Family L.L.C. 
ATTN: Julie A. Johnson 
9702 West Glendale Avenue 
Glendale, Arizona 85305 
 
with a copy to: 
 
David J. Armstrong, Esq. 
Ballard Spahr LLP 
One East Washington Street, Suite 2300 
Phoenix, Arizona 85004 
 
To City of Glendale: 
 
Nancy A. Mangone, Esq.  
Deputy City Attorney  
City of Glendale, Arizona 
5850 W. Glendale Avenue 
Glendale, Arizona 85301 
 
with a copy to: 
 
Elizabeth H. Temkin, Esq. 
David Graham & Stubbs 
1550 17th Street, Suite 500 
Denver, CO 80202

EXHIBIT A 
 
The Johnson Property

EXHIBIT B 
 
Easement

When recorded, mail to: 
 
 
 
 
 
City Clerk, City of Glendale 
5850 West Glendale Avenue 
Glendale, Arizona 85301 
 
 
EASEMENT AGREEMENT 
________________________________ 
______________________________________________ 
 
 
THIS EASEMENT AGREEMENT (this “Agreement”) is made this ______ day of 
____________________, 20__ (the “Effective Date”), by and between the CITY OF GLENDALE, an 
Arizona municipal corporation (“Grantor”), and RUDOLPH JOHNSON FAMILY, LLC, an Arizona 
limited liability company (“Grantee”).  Grantor and Grantee are sometimes referred to herein collectively 
as the “Parties” and individually as a “Party”. 
 
RECITALS 
Grantor owns certain real property as described and depicted on Exhibit A, attached hereto and made 
a part hereof (the “Grantor Property”). Reference to “Grantor” herein shall be deemed to mean and refer to 
the owner of the fee simple title from time to time of the Grantor Property. 
Grantee owns certain real property as described and depicted on Exhibit B, attached hereto and made 
a part hereof (the “Grantee Property”). 
Grantor has agreed to grant to Grantee, a non-exclusive easement upon and across that portion of 
the Grantor Property as legally described and depicted on Exhibit C, attached hereto and made a part hereof 
(the “Easement Area”), for the sole purpose of transporting irrigation water through, and the repair and 
maintenance of, an existing irrigation system located within the Easement Area on the Effective Date solely 
for agricultural purposes (i.e., growing, cultivating and harvesting crops or as pastureland for livestock) (the 
“Permitted Use”). 
 
AGREEMENT 
NOW, THEREFORE, in consideration of the mutual covenants and agreements herein contained, 
and for other good and valuable consideration, the sufficiency of which is hereby acknowledged, the Parties 
represent and agree as follows: 
1. 
Grant of Easement. For Ten Dollars and other valuable consideration set forth herein, 
Grantor does hereby convey to Grantee a non-exclusive easement (the “Easement”) across the Easement 
Area for the sole purpose of the Permitted Use. 
 
2. 
Term. The Easement granted hereunder shall commence on the Effective Date and continue 
for so long as the Grantee Property is used solely for agricultural purposes (i.e., growing, cultivating and 
harvesting crops or as pastureland for livestock).  The Easement shall be terminated (i) by mutual consent 
of the then-current owner of the Grantor Property and Grantee, or (ii) by operation of law, in the event that 
Grantee ceases to use the Easement Area for the Permitted Use for any continuous two (2) year period 
during the term of the Easement; provided, however, that such two (2) year period shall be tolled during

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any period when there is not a sufficient supply of water available to use the Easement for the Permitted 
Use for the benefit of the Grantee Property.   
 
3. 
Maintenance. 
 
(a) 
Grantee shall, at its sole cost and expense, repair and maintain the Easement Area in 
good order, condition, and repair, and in compliance with all applicable laws, statutes, ordinances, 
governmental rules or regulations now in force or hereafter enacted by any applicable governmental 
or quasi-governmental authorities having jurisdiction over the Grantor Property. Grantee shall 
promptly repair any damage to the Easement Area caused by the acts (whether negligent, willful, or 
otherwise) of Grantee or its tenants, lessees, agents, employees, licensees, or any other third-parties 
(collectively, the “Permittees”), except to the extent any such damage is caused by the gross  
negligence or intentional misconduct of Grantor or its tenants, lessees, agents, employees, or 
licensees. 
 
(b) 
In the event that Grantee fails to maintain the Easement Area in accordance with this 
Section 3 or any other provision of this Agreement, and after thirty (30) days’ written notice from 
Grantor, Grantee has not commenced repairs, replacements, or maintenance thereof (except in the 
case of an emergency, in which case no such prior notice by Grantor shall be required), Grantor may 
perform the required repair, replacement, or maintenance and shall bill Grantee for all costs incurred 
by Grantor in connection therewith. Reimbursement of any such amount shall be payable, in full, 
within twenty (20) days after the date of the Grantor’s bill. Any such Reimbursement does not 
excuse, prohibit or otherwise affect any and all claims Grantor could bring under Section 6 below. 
4. 
Nature of Easement. 
(a) 
The Easement herein granted will be non-exclusive, and Grantor expressly reserves 
the right, without materially interfering with or materially abridging the rights granted herein to 
Grantee, to the use, enjoyment, and occupancy of the surface of and all other portions of the 
Easement Area and Grantor Property for any and all purposes that are not inconsistent with the terms 
of this Agreement and the rights and interests afforded to Grantee under the terms hereof. Grantee 
may use the Easement solely for the Permitted Use and for no other purposes.  
(b) 
Grantor shall have the right to access and enter the Easement Area to monitor the use 
and condition thereof, at its sole cost and expense, for the purpose of confirming compliance with 
the terms and conditions of this Agreement.  In the event that Grantor determines that (i) the 
Easement Area is being improperly maintained, operated or used by Grantee or its Permittees, or 
(ii) circumstances exist that would give rise to the need for repair, replacement, security or additional 
monitoring of the Easement Area, Grantor shall notify Grantee of such circumstances, and Grantee 
shall immediately halt such improper use and address such non-complying conditions. In the event 
of a breach of the rights granted or created under this Agreement, Grantor shall, in addition to all 
other remedies available to it, be entitled to enforce this Agreement by injunctive relief or otherwise. 
(c) 
In the event of a transfer or assignment by Grantor of its interest in the Grantor 
Property, Grantor, without the necessity of any further document signed or actions taken by any 
party, shall be released from any and all obligations hereunder arising on or after, but not prior to,

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the date of transfer, and each party benefited hereby thereafter agrees to look solely to the successor-
in-interest of Grantor for performance of such obligations. 
5. 
Liens. Grantee shall protect the Easement Area and the Grantor Property from mechanic’s, 
materialmens’, and other liens arising in connection with maintenance of the Easement Area or the Grantor 
Property and any structures or improvements thereon, and to indemnify and defend Grantor and its 
successors and assigns from and against and with respect to any such liens and to cause any such lien to be 
removed by payment or bonding within thirty (30) days of recording thereof. 
6. 
Release; Indemnity. The use, maintenance, or repair of the Easement Area and any structure 
or improvement thereon and enjoyment of the Easement Area pursuant to this Agreement shall be at the 
sole risk of Grantee.  Grantee shall indemnify, defend, and hold harmless Grantor from and against any and 
all claims, suits, actions, debts, damages, costs, losses, obligations, death, injury to persons or property or 
liabilities (including reasonable attorneys’ fees and costs) arising from the breach of this Agreement by the 
Grantee or its Permittees, or the use of the Easement Area or any other portion of the Grantor Property by 
Grantee or its Permittees, except to the extent that any such loss is caused by the gross negligence, 
intentional misconduct, or breach of this agreement by Grantor or its tenants, lessees, agents, employees, 
or licensees. 
 
7. 
Improvements; Temporary Construction Easement. Notwithstanding anything to the 
contrary set forth in this Agreement, Grantee shall not place in the Easement Area any permanent or 
temporary structures or other improvements other than those improvements which constitute the existing 
irrigation system located in the Easement Area on the Effective Date. In the event Grantee wishes to replace, 
improve or upgrade any existing improvements or install new facilities, structures or improvements, Grantor 
and Grantee shall use commercially reasonable efforts to negotiate and enter into in good faith and in a 
timely manner, an agreement that allows for the permanent placement of such replaced, improved, upgraded 
or new facilities, structures or improvements and a temporary construction easement in order to facilitate 
Grantee’s construction or reconstruction activities; provided, however, that such activities (i) shall not 
unreasonably interfere with Grantor’s use of the Grantor Property, and (ii) shall be subject to Grantor’s 
review and approval of all construction plans in connection therewith without charge or cost to Grantor.   
8. 
No Public Dedication. Nothing contained in this Agreement shall be deemed a gift or 
dedication of any portion of the Easement Area to the general public or for the general public or for any 
public purposes whatsoever, it being the intention of the Parties that this Agreement and the Easement shall 
be strictly limited to and for the purposes herein expressed. There are no intended third-party beneficiaries 
to this Agreement. 
9. 
Relationship of the Parties. None of the terms or provisions of this Agreement create a 
partnership between or among the parties in their respective businesses or otherwise, or constitute the 
Parties as joint venturers or members of any joint enterprise.  Each party to this Agreement shall be 
considered a separate owning entity and no party shall have the right to act as agent for another party unless 
expressly authorized to do so by written instrument signed by the authorized party. 
10. 
Default and Remedies.   
(a) 
If a Party defaults on any obligation under this Agreement, and such default remains 
uncured for thirty (30) days following delivery of notice from the non-defaulting Party to the 
defaulting Party (or, if such default cannot reasonably be cured within a thirty (30) day period, an 
appropriate cure is not commenced and diligently pursued within such thirty (30) day period), then

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the non-defaulting Party may seek any and all such relief as may be available at law or equity for 
the default.  
(b) 
In addition to the remedies set forth in Section 10(a) above, if within thirty (30) days 
after receipt of such notice, the defaulting party has not cured the default (or, if such default cannot 
reasonably be cured within a thirty (30) day period, has not commenced the diligent pursuit of an 
appropriate cure in such thirty (30) day period), the non-defaulting Party may take such actions 
and/or expend such funds as are reasonably necessary to cure such default. In such event, the non-
defaulting Party incurring costs to cure shall be entitled to recover from the defaulting Party such 
costs as are actually and reasonably incurred in curing the default, the aggregate amount of which 
shall be due immediately upon notice to the defaulting Party.  
(c) 
In the event of any litigation between the Parties relating to this Agreement, the 
prevailing Party will be entitled to recover its court costs and reasonable attorneys’ fees.  
11. 
Notices.  All notices, demands and other communications required or permitted to be given 
hereunder will be in writing and any and all such items will be deemed to have been duly delivered as 
follows: (i) upon personal delivery; (ii) as of the third (3rd) business day after mailing by United States 
mail, certified, return receipt requested, postage prepaid, addressed as follows; (iii) as of 12:00 p.m. local 
time on the immediately following business day after deposit with FedEx or a similar overnight courier 
service, addressed as follows; or (iv) after transmitting by facsimile or e-mail to the facsimile number or e-
mail address set forth below: 
 
If to Grantor: 
Field Operations 
6210 W. Myrtle Avenue, Suite 111 
Glendale, AZ 85301 
 
with a copy to: 
 
City Attorney  
City of Glendale, Arizona 
5850 W. Glendale Avenue 
Glendale, Arizona 85301 
 
If to Grantee: 
_______________________ 
_______________________ 
_______________________ 
E-mail:_________________ 
 
Any address, facsimile number or e-mail address fixed pursuant to the foregoing may be changed by the 
addressee by notice given pursuant to this Section 11. 
 
12. 
Insurance. Grantee shall obtain and maintain, and shall ensure that its Permittees obtain and 
maintain, at all times during the term of the Easement, commercial general liability insurance in

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commercially reasonable amounts for its use of the Easement, covering Grantee’s interest in and use of the 
Easement.  
 
13. 
Severability.  If any term, covenant, condition, or provision of this Agreement is, at any time 
or to any extent, declared invalid or unenforceable, the remainder of this Agreement will not be affected 
thereby, it being the intent of the Parties that this Agreement and each provision hereof will be enforceable 
and enforced to the fullest extent permitted by law. 
 
14. 
Entire Agreement.  This Agreement and any other contracts or agreements specifically 
referred to herein represent the entire agreement between the Parties with respect to the subject matter 
hereof and all prior or extrinsic agreements, understandings, or negotiations will be deemed merged herein. 
 
15. 
Governing Law.  This Agreement will be governed by and construed in accordance with the 
laws of the State of Arizona, without reference to its conflict of laws provisions.  
 
16. 
Modification and Waiver.  No purported modification of the terms of this Agreement, or 
purported waiver by any Party of its rights and interests hereunder, will be binding unless and except to the 
extent specifically set forth in a written instrument executed by the party against whom enforcement of the 
purported modification or waiver is sought. 
 
17. 
Counterparts.  This Agreement may be executed in counterparts, each of which will be 
deemed an original, and all of which together will constitute one and the same instrument and agreement.  
 
18. 
Binding Effect. For the term of the Easement, this Agreement shall be binding upon the 
Parties and their successors and assigns. 
 
(Signature pages follow)

6  
 
IN WITNESS WHEREOF, the Parties have made and entered into this Agreement as of the 
Effective Date. 
GRANTOR: 
 
CITY OF GLENDALE, 
an Arizona municipal corporation 
 
 
 
 
 
 
 
By: ___________________________ 
 
 
 
 
 
 
Name: _________________________ 
 
 
 
 
 
 
Title:__________________________ 
 
 
 
 
 
  
Exempt Pursuant to A.R.S.§11-1134(A)(2),  
11-1134(A)(3) 
 
STATE OF ARIZONA 
) 
 
)  ss. 
County of Maricopa  
) 
 
The foregoing instrument was acknowledged before me this           day of                        , 202_ 
by__________________,  ____________________, who acknowledged that she executed this instrument 
for the purposes therein contained. 
 
 
 
 
 
 
 
 
 
 
 
   
 
Notary Public 
My commission expires:  
(Grantee signature page follows)

7  
 
IN WITNESS WHEREOF, the Parties have made and entered into this Agreement as of the 
Effective Date. 
 
GRANTEE: 
RUDOLPH JOHNSON FAMILY, LLC, 
an Arizona limited liability company 
 
 
 
 
 
 
 
 
 
 
 
 
 
By: ___________________________ 
 
 
 
 
 
 
Name: _________________________ 
 
 
 
 
 
 
Title: __________________________ 
 
 
Exempt Pursuant to A.R.S.§11-1134(A)(2),  
11-1134(A)(3) 
 
STATE OF ARIZONA 
) 
 
)  ss. 
County of Maricopa  
) 
 
The foregoing instrument was acknowledged before me this           day of                       , 202_ 
by__________________,  ____________________, who acknowledged that she executed this instrument 
for the purposes therein contained. 
 
 
 
 
 
 
 
 
 
 
 
   
 
Notary Public 
My commission expires:

8  
 
Exhibit A 
 
Grantor Property

9  
 
Exhibit B 
 
Grantee Property

10  
 
Exhibit C 
 
Easement Area

EXHIBIT C 
 
Joint Notice of Dismissal

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David J. Armstrong 
BALLARD SPAHR LLP 
1 East Washington Street, Suite 2300 
Phoenix, AZ 85004-2555 
Telephone: 602.798.5400 
Facsimile: 602.798.5595 
Attorneys for Plaintiff 
Rudolph Johnson Family L.L.C. 
 
Elizabeth H. Temkin 
James R. Henderson 
DAVIS GRAHAM & STUBBS LLP 
1550 17th Street, Suite 500 
Denver, CO 80202 
Telephone: 303.892.9400 
Facsimile: 303.893.1379 
Attorneys for Defendant City of Glendale 
THE UNITED STATES DISTRICT COURT  
FOR THE DISTRICT OF ARIZONA 
Rudolph Johnson Family L.L.C., an Arizona 
limited liability company, 
Plaintiff, 
vs. 
City of Glendale, an Arizona municipal 
corporation, 
Defendant. 
) 
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Case No. 
2:19-cv-05905-PHX-SRB 
 
JOINT NOTICE OF DISMISSAL 
WITH PREJUDICE 
 
 
Pursuant to Fed. R. Civ. P. 41(a)(1), Plaintiff Rudolph Johnson Family L.L.C. and 
Defendant City of Glendale (collectively, the “Parties”) stipulate that all claims asserted 
against the City of Glendale in this action shall be hereby dismissed with prejudice, all 
Parties to bear their own attorneys’ fees and costs.

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DATED: ___________, 2022 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
David J. Armstrong  
 
 
Elizabeth H. Temkin 
BALLARD SPAHR LLP  
 
James R. Henderson 
 
 
 
 
 
 
DAVIS GRAHAM & STUBBS LLP 
 
Attorneys for Plaintiff 
 
 
Attorneys for Defendant 
Rudolph Johnson Family L.L.C.  
City of Glendale