SETTLEMENT AND MUTUAL RELEASE AGREEMENT WITH TRES RIOS GOLF LLC.PDF

Maricopa County — Formal (2020-09-16)

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Settlement and Mutual Release Agreement 
 
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SETTLEMENT AND  
MUTUAL RELEASE AGREEMENT 
 
This SETTLEMENT AND MUTUAL RELEASE AGREEMENT (this “Settlement 
Agreement”), dated this _____ day of September, 2020 (the “Effective Date”), is entered into by 
and between Maricopa County, a political subdivision of the State of Arizona (“County”) and 
Tres Rios Golf, LLC, an Arizona limited liability company (“Concessionaire”). County and 
Concessionaire are collectively referred to hereinafter as the “Parties.” 
 
RECITALS 
 
 
WHEREAS, County entered into Amendment Three to Estrella Mountain Park Golf 
Course Use and Management Agreement (“Agreement”) for the Management, Operation, 
Maintenance and Improvement of the Golf Course Concession – Tres Rios Golf Course at 
Estrella Mountain Park Formerly Known as Estrella Mountain Park Golf Course dated March 16, 
2011 (C-30-04-027-1-01), which amended and restated the Use Management Agreement dated 
March 12, 1997, Amendment One dated January 6, 1999 and Amendment Two dated June 16, 
2004; and 
 
 
WHEREAS, on April 25, 2012, County approved the assignment of the Agreement to 
Concessionaire and on August 17, 2016, County and Concessionaire entered into Amendment 
Four to the Use Management Agreement (Amendment Four and the Agreement collectively 
referred to as the “Agreement”); and 
 
 
WHEREAS, County and Concessionaire have determined that it is in the best interest of 
the parties to allow Concessionaire to be released from its obligations pursuant to the Agreement; 
and 
 
 
WHEREAS, County and Concessionaire have reached an agreement on the final 
amounts due pursuant to Agreement, and now wish to document that agreement with this 
Settlement Agreement and to release any and all claims against each other and resolve any and 
all obligations to each other regarding the matters addressed herein;  
 
NOW THEREFORE, in consideration of the mutual promises, covenants, and 
agreements contained herein, the receipt and adequacy of which are hereby acknowledged, the 
Parties hereby agree as follows. 
 
TERMS 
 
1. 
Final Settlement of Amounts Due Pursuant to the Agreement.  The Parties 
hereby agree, to fully and finally resolve any and all amounts that are or may be due under the 
Agreement and to fully and finally resolve any and all claims between the Parties regarding the 
amounts that are or may be due under the Agreement, Concessionaire shall pay to County the 
sum of Thirty-Three Thousand, Eight Hundred Seventy Dollars and 99/100 ($33,870.99) (the 
“Settlement Sum”).  The Settlement Sum shall be paid in lawful money of the United States to 
County by a check made payable to County and remitted to the following address:

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Maricopa County 
41835 N. Castle Hot Springs Road 
Morristown, Arizona  85342 
Attn: Emily Miller 
 
2. 
Mutual Release.  Except as otherwise provided in this Settlement Agreement, in 
consideration for (i) the Parties fully and finally resolving any and all amounts that are or may be 
due under the Agreement and fully and finally resolving any and all claims between the Parties 
regarding the Agreement, (ii) the payment of the Settlement Sum, and (iii) the other promises, 
covenants and agreements contained in this Settlement Agreement, each of the Parties, for 
themselves, and on behalf of their respective current and former officers, directors, members, 
members of members, shareholders, partners, affiliates, subsidiaries, parent companies, agents, 
attorneys, representatives, predecessors, successors and assigns (each, a “Releasing Party” and 
collectively, the “Releasing Parties”), absolutely and unconditionally waive, release and forever 
discharge each of the Parties and their respective current and former officers, directors, members, 
members of members, shareholders, partners, affiliates, subsidiaries, parent companies, agents, 
attorneys, representatives, predecessors, successors and assigns (each, a “Released Party” and 
collectively, the “Released Parties”), from all claims, demands, obligations, liabilities, actions, 
and causes of actions whatsoever, in law or equity, that any Releasing Party has, ever had, or 
may in the future have against any of the Released Parties, arising from or in any way relating to 
(i) the Agreement, and (ii) any and all disputes between the Parties as of the Effective Date of 
this Settlement Agreement regarding, or in any way relating to the Agreement.  Each of the 
Releasing Parties acknowledge and agree that this is a general release that expressly covers 
unknown as well as known claims regarding, in any way, amounts due under the Agreement, and 
each of the Releasing Parties voluntarily waive, release and assume the risk of all claims that 
exist as of the Effective Date, whether known or unknown to them regarding, in any way, the 
Agreement.   
3. 
Non-Disparagement.  As of the Effective Date of this Settlement Agreement, the 
Parties respectively agree not to make any statements, written or verbal, or cause or encourage 
others to make any statements, written or verbal, that defame, disparage or in any way criticize 
the reputation, practices or conduct of any Party to this Settlement Agreement, including any 
Party’s current and former officers, directors, shareholders, partners, affiliates, agents, attorneys, 
representatives, predecessors, successors and assigns.  The Parties acknowledge and agree that 
this prohibition continues in perpetuity and extends to statements, written or verbal, made to 
anyone, including but not limited to, the news media.  
4. 
No Admission of Liability.  The Parties acknowledge that they are entering into 
this Settlement Agreement to fully and finally resolve any and all matters under the Agreement, 
and that nothing contained herein shall be construed to be an admission of liability. Each Party 
expressly denies any liability to the other Parties. 
5. 
No Reliance; Negotiations and Drafting.  This Settlement Agreement is entered 
into with full awareness and consideration of any and all rights the Parties currently have or may 
have.  Each of the Parties has read this Settlement Agreement and has relied upon their own 
respective knowledge and independent judgment in executing this Settlement Agreement. None 
of the Parties are relying upon any representations, promises or statements made by any of the

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other Parties or their respective agents, representatives, servants, or employees as having induced 
it with regard to the subject matter hereof to sign this Settlement Agreement. Each of the Parties 
has participated in the negotiations and drafting of this Settlement Agreement.  None of the 
Parties shall be deemed the “author” for the purposes of the construction of this Settlement 
Agreement or any part thereof.  
6. 
Authority.  Each signatory to this Settlement Agreement has read and fully 
understands this Settlement Agreement, is fully authorized and empowered to enter into this 
Settlement Agreement, is duly authorized to execute this Settlement Agreement and to bind each 
of the Parties to the terms and conditions herein, and all approvals necessary to enter into this 
Settlement Agreement have been obtained. 
7. 
No Third Party Consent.  Each of the Parties represents and warrants to the 
other Party that the execution, delivery and performance by the Parties of this Settlement 
Agreement does not require the consent of any third party. 
8. 
Severability.  In the event that any material provision of this Settlement 
Agreement is held invalid, the remainder of this Settlement Agreement shall remain fully 
enforceable. Any term or provision of this Settlement Agreement that is invalid or unenforceable 
shall not affect the validity or enforceability of the remaining terms and provisions hereto or the 
validity or enforceability of the offending term or provision in any other jurisdiction. 
9. 
Integration.  This Settlement Agreement constitutes the complete and final 
agreement between the Parties with regard to the subject matter hereof and supersedes and 
cancels all prior or contemporaneous agreements, understandings, discussions, or representations 
regarding the subject matter of this Settlement Agreement. 
10. 
Modification.  This Settlement Agreement may not be modified or amended, nor 
any of its terms waived, except by written instrument signed by each of the Parties hereto. 
11. 
Choice of Law; Attorneys’ Fees; Venue.  The interpretation and construction of 
this Settlement Agreement shall be governed by and construed in accordance with the 
substantive law of the State of Arizona, to the extent the particular subject matter is controlled by 
state law, and without regard to conflicts of law particular to the subject matter. The prevailing 
party in any dispute resulting from the interpretation of this Settlement Agreement or breach 
thereof shall be entitled to be reimbursed from the non-prevailing party for its attorneys’ fees and 
expenses. Exclusive venue, if a dispute arises out of this Settlement Agreement, shall be in 
Maricopa County, Arizona. 
12. 
Legal Fees.  Each Party agrees to be solely responsible for its legal fees incurred 
in connection with the negotiation, preparation, review and execution of this Settlement 
Agreement. In the event that any Party is required to seek judicial intervention in order to 
enforce this Settlement Agreement, the prevailing Party in such an enforcement action shall be 
entitled to recover its reasonable attorneys’ fees and costs.  
13. 
Notices.  All communications, notices and consents provided for herein (a 
“Notice”) shall be in writing and be given in person or by means of telex, telecopy, or other wire 
transmission (with request for assurance of receipt in a manner typical with respect to

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communications of that type) or by nationally recognized overnight courier (the “Courier”) for 
next business day delivery, and shall become effective (i) on delivery if given in person, (ii) on 
the date of transmission if sent by telex, telecopy, or other wire transmission, or (iii) the business 
day following delivery of the Notice to the Courier, with proper postage prepaid.  Notices shall 
be addressed as follows: 
If to County: 
 
Maricopa County 
41835 N. Castle Hot Springs Road 
Morristown, Arizona  85342 
Attn: Emily Miller 
 
If to Concessionaire: 
 
Tres Rios Golf, LLC 
1245 E. Warner Road, Suite 202 
Gilbert, Arizona  85296 
 
With a copy to: 
 
Addison Law Firm 
5400 LBJ Freeway, Suite 1325 
Dallas, Texas 75240 
Attn: Timothy J. Clow 
 
14. 
Counterparts.  This Settlement Agreement may be executed in one or more 
counterparts, each of which, when so executed, shall be deemed to be an original; such 
counterparts, when so executed together, shall constitute one and the same Settlement Agreement 
and shall be deemed to be an original.  Photographic, faxed or electronic copies of such signed 
counterparts shall constitute originals for the purpose of this Settlement Agreement and may be 
used in lieu of the originals for any purpose. 
15. 
Cooperation.  The Parties shall each deliver or cause to be delivered to the other 
on the Effective Date, and at such other times and places as shall be reasonably agreed to, such 
additional instruments as the other may reasonably request for the purpose of carrying out this 
Settlement Agreement.  The provisions of this Section 16 shall survive the Effective Date. 
 
[Signatures on Following Page]

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IN WITNESS WHEREOF, the Parties hereto have caused this instrument to be 
EXECUTED by their duly authorized representatives and to be effective as of the Effective Date 
of this Settlement Agreement. 
 
COUNTY: 
 
 
 
 
 
CONCESSIONAIRE:
 
MARICOPA COUNTY, 
 
 
 
TRES RIOS GOLF, LLC, 
a political subdivision of the State of Arizona 
an Arizona limited liability company 
 
 
By:_______________________________ 
 
By:_______________________________ 
Name:_____________________________  
Name:_____________________________ 
Title:______________________________  
Title:______________________________