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City of Scottsdale — Regular Meeting (2026-06-09)

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Item 19
CITY COUNCIl
REPORT
m
Meeting Date:
General Plan Element: 
General Plan Goal:
ACTION
June 9, 2026
Provide for the orderly administration of the affairs of the City 
Fiscal management
Adopt Resolution No. 13705 authorizing:
(1) The Mayor to execute Contract No. 2026-113-COS on behalf of the City to settle 
Beverly Tyson's claims in the amount of Thiily-Four Thousand Eight Hundred 
Twelve Dollars and 20/100 Cents ($34,812.20) from funds to be paid from the 
City's Safety & Risk Management Operating Budget, and
(2) That the City Council authorizes and directs the City Manager, the City Treasurer, 
and the City Attorney, and their respective staffs to execute such documents and 
take such other actions as are necessary to carry out the purpose of the Resolution.
BACKGROUND
On February 25, 2026, claimant Beverly Tyson was driving her 2026 GMG Terrain Elevation on 
Hayden Rd. She started to slow down to allow the vehicle in front of her to turn right onto Osborn 
Rd. Ms. Tyson alleges that as she slowed her vehicle, she was struck from behind by a Scottsdale 
Police Department Vehicle. The impact caused damage to both vehicles. Fortunately, Ms. Tyson 
was not injured in the event.
Ms. Tyson filed a notice of claim and presented the City with an estimate to repair her vehicle. 
The Safety & Risk Management Division utilized its Contractor, Crawford and Company, to 
complete an independent review of the estimate and an analysis of the vehicle's Actual Cash 
Value. A teardown of the vehicle was conducted to determine hidden damage. This resulted in a 
supplemental total estimate to repair in the amount of $32,435.23: The Actual Cash Value of the 
vehicle was less ($31,542.48), so the vehicle was declared a total loss. The damages allegedly 
caused by the impact areas follows:
Actual Cash Value: 
$31,542.48
Tear Down & Towing Fess: 
$ 1,497.00
Rental: 
$ 
772.72
Loss of Use: 
$ 1.000.00
Total: 
$34,812.20
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The City has offered, contingent upon City Council approval, the sum of $34,812.20 to settle Ms. 
Tyson's claims against the City.
ANALYSIS & ASSESSMENT
Recent Staff Action
The claim has been analyzed by the City’s Safety & Risk Management Division. The damages were 
independently evaluated, and the costs submitted by the Claimant align closely with the City's 
assessment. Settlement of this claim avoids the risk and costs of prolonged litigation. Safey & 
Risk Management recommends this settlement as being in the best interests of the City.
Policy Implications
None.
Significant Issues to be Addressed
None.
Community Involvement
No community involvement is necessary on this item.
RESOURCE IMPACTS
Available funding
The proposed settlement will require a total payment of $34,812.20 from the City to Ms. Tyson. 
Funds are available in the City's FY 2025/26 Safety & Risk Management operating budget to pay 
the settlement.
Staffing, Workload Impact
Approval of this settlement will conclude the matter and avoid additional staff time from the City 
Attorney's office. Safety & Risk Management Division, and other departments.
Future Budget Implications
The proposed settlement may be included in the City's primary property tax rate for next fiscal 
year. The City of Scottsdale has a long-standing practice of including paid tort settlements equal 
to or greater than $20,000 in the City's primary tax rate to reimburse the Self-Insured Risk 
Management Fund.
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OPTIONS & STAFF RECOMMENDATION
Recommended Approach
Adopt Resolution No. 13705, approving Agreement No. 2026-113-COS and authorizing the 
settlement of Claimant's claim against the City for $34,812.20.
Proposed Next Steps
If the Agreement is approved. City representative(s) will take steps necessary to finalize the 
settlement and issue payment to the Claimant.
RESPONSIBLE DEPARTMENT(S)
City Attorney’s Office- Civil and Safety & Risk Management Divisions
STAFF CONTACTS (S)
George Woods, Jr., Safety & Risk Management Director
(480) 312-7040
gwoods@scottsdaleaz.gov
Luis E. Santaella, City Attorney 
(480) 312-2405 
lsantaella@scottsdaleaz.gov
APPROVED BY
George Wood 
(480) 312-70 
gwoods@scottsdal^z.gov
., Safety and Risk Management Director
Date
Luis E. Santaella, City Attorney 
(480) 312-7771 
lsantaella@scottsdaleaz.gov
Date
ATTACHMENTS
1. Resolution No. 13705
2. Contract No. 2026-113-COS
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RESOLUTION NO. 13705
A RESOLUTION OF THE COUNCIL OF THE CITY OF SCOTTSDALE. 
MARICOPA COUNTY, ARIZONA, AUTHORIZING SETTLEMENT IN 
THE AMOUNT OF $34,812.20 OF THE CLAIM OF BEVERY TYSON,
AND AUTHORIZING THE MAYOR TO EXECUTE CONTRACT NO.
2026-113-COS.
WHEREAS, Beverly Tyson filed a claim asserting liability against the City and 
seeking to recover for damages allegedly suffered because of a traffic collision on or 
about February 25, 2026 (“the Claim”); and
WHEREAS, the City continues to dispute liability, but it is in the best interest of the 
City to effectuate a settlement of all claims agaihst the City arising from the subject traffic 
collision: and
WHEREAS, the parties have agreed to resolve the disputed issues and 
compromise all claims by settling herein.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of Scottsdale, 
Maricopa County, Arizona, as follov\/s:
Section 1. That the City Council hereby approves this settlement and authorizes 
the Mayor to execute Contract No. 2026-113-COS on behalf of the City to settle Beverly 
Tyson’s clairns in the amount of Thirty-Four Thousand Eight Hundred Twelve Dollars and 
20/100 Cents ($34,812.20) from funds to be paid from the City’s Safety & Risk 
Management Operating Budget.
Section 2. That the City Council authorizes and directs the City Manager, the City 
Treasurer, and the City Attorney, and their respective staffs to execute such documents 
and take such other actions as are necessary to carry out the purpose of the Resolution.
PASSED AND ADOPTED by the Council of the City of Scottsdale, Maricopa 
County, Arizona this_______day of June, 2026.
CITY OF SCOTTSDALE, an Arizona 
municipal corporation
Lisa Borowsky, Mayor
Resolution No. 13705 
Page 1 of 2
ATTACHMENT 1

ATTEST:
Ben Lane, City Clerk
APPROVED AS TO FQRM
r
7
ttfis^pi^antaefa.'^ity Attorney 
By: Lori S, Davis, Chief Deputy City Attorney
Resolution No. 13705 
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Contract No. 2026-113-COS
1
SETTLEMENT AGREEMENT 
AND GENERAL RELEASE
This Settlement Agreement and General Release of All Claims (“Agreement”) is entered 
into by and between BEVERLY TYSON (“Claimant”) and the CITY OF SCOTTSDALE, a 
municipal corporation, its employees, officers, and agents, including, but not limited to. Officer 
Ava Moniz, the City and its employees, named and unnamed, collectively known as “City”. 
Claimant and City may be referred to jointly as the “Parties”.
RECITALS
A. 
On or about February 25, 2026 Claimant alleges that she was driving her 2026 
GMC Terrain Elevation bn Osborn Rd. She started to slow down to allow the vehicle in frOht of 
her to turn right. Ms. Tyson alleges that as she slowed her vehicle, she was struck from behind by 
a Scottsdale Police Department Vehicle, (collectively hereinafter referred to as “event”).
B. 
Claimant filed a Notice of Claim with the City on or about M^ch 19,2026 alleging 
injiuy and damage she allegedly sustained in the event.
C. 
Despite the fact that liability has not been admitted regarding the claim asserted by 
Claimant and the fact that her claims remain disputed. Claimant desires to finally and fully resolve 
all past, present, and potential disputes, clairhs, and issues between the Parties relating to or arising 
out of the event and the facts and circumstances that gave rise to the Claimant’ s alleged injuries. 
The Claimant and the City desire to avoid further expense, inconvenience, and the distraction of 
burdensome and protracted litigation. This Agreement is intended to resolve any dispute which 
may exist between the Parties. The Claimant intends to execute this Agreement in order to provide 
for certain payment in full settlement and discharge of all claims which are, or might have been, 
brought against the City as a result of the event,' upon the terms and conditions set forth below.
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ATTACHMENT2

Contract No. 2026-113-COS
AGREEMENT
In consideration of the promises and releases set forth herein, the Parties agree as follows:
1. 
Settlement Payment. The total payment by the City for the settlement of this claim 
shall be THIRTY-FOUR THOUSAND EIGHT HUNDRED TWELVE DOLLARS and 20/100 
($34,812.20) which includes any and all claims for costs and attorneys’ fees, if any, with the 
payment to be made to “Beverly Tyson”; Claimant acknowledges and agrees that this settlement 
payment is the full and entire amount that Claimant will ever receive from the City in connection 
with the claims and event described above.
2. 
All Claims of Any Kind. In consideration for the terms and promises herein. 
Claimant hereby fully and generally releases and forever discharges the City, its officers, 
employees and agents, from any and all claims or liabilities of any nature whatsoever to the extent 
allowed by lavy that Claimant has or claims to have, or may have, against any of them arising out 
of the event including any expenses and attorneys’ fees, regardless of whether or not such claims 
or liabilities are known to the P^ies at the time of the execution of this Agreement. Claimant 
intends by the execution of this Agreement to release all claims against the City and its employees, 
officers, and agents including any unknown damages and/or injuries.
3. 
No Admission of Liability. It is rmderstood and expressly agreed that neither the
payment of the Settlement Payment nor anything contained within this Agreement shall be
1
construed as an admission of any liability whatsoever on the part of the City vyhich has always and 
is now expressly denying any liability. The Parties acknowledge and agree that the Settlement 
Payment is made in compromise and settlement of a disputed claim.
4. 
Liens. Claimant warrants that Claimant will satisfy any and all valid liens, 
includiug, but not limited to, ERISA liens. Medicare or Medicaid liens, liens pursuant to A.R.S. §
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Contract No. 2026-113-COS
33-931 et seq., liens falling under the rubric of Andrews v. Samaritan Health System, 201 Ariz. 
379, 36 P.3d 57 (App. 2001); Blankenbaker v. Jonovich, 205, Ariz. 383, 71 P.3d 910 (Ariz. 2003); 
Maricopa County v. Barfield, 75 P.3d 714 (App. 2003). Claimant will indemnify and hold 
harmless the City, its employees, officers, agents and representatives, from any and all claims, 
demands, actions and causes of action, and all liability whatsoever, including, but not limited to 
costs, attorneys’ fees or judgment which might arise from an unpaid or unsatisfied hospital or 
medical bill and/or lien or lien of any other kind which might apply to the proceeds paid herein.
5. 
Indemnify and Hold Harmless. Claimant does hereby covenant to indemnify and 
saye harmless the City from and against all claims and demands whatsoever on account of or in 
any way growing out of the event or its results both to person and property.
6. 
General Release. Claimant acknowledges and agrees that this is a General Release. 
The Claimant expressly waives and assumes the risk of any and all claims for damages which exist 
of this date, but of which the Claimant does not know or suspect to exist, whether through 
ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect 
the Claimant’s decision to execute this Release. The Claimant further agrees that Claimant has 
accepted payment of the sum specified herein as a complete settlement and compromise of matters 
involving disputed issues of law and fact. The Claimant assumes the risk that the facts or law may 
be other than Claimant believes. The Claimant understands and agrees that this Agreement is a 
compromise of disputed claim, and the Settlement Payment is not to be construed as an admission 
of liability on the part of the City, by whom liability is expressly denied.
7. 
Review of Agreement The Claimant declares and represents that no promise, 
inducement or agreement not herem expressed has been made to the Claimant and the terms of 
this Agreement are contractual and not a mere recital. The Parties expressly acknowledge that they
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Contract No. 2026-113-COS
have entered this Agreement knowingly and voluntarily and that each party has had the opportunity 
to receive the advice of counsel with respect to the Agreement and the settlement of this matter.
8. 
Binding Nature of Agreement;^ Assignment. This Agreement shall be binding upon 
and inure to the benefit of the Parties and their respective heirs, personal representatives, 
successors and assigns, except that no party may assign, delegate or transfer any of its rights or 
obligations under this Agreement without prior written consent of the other party.
9. 
Arizona Law. In the event of any dispute arising from the terms of this Agreement, 
Arizona law shall apply and govern.
10. 
Entire Agreement. Tins Agreement constitutes the entire integrated agreement 
between the Parties and supersedes any and all prior and/or contemporaneous agreements, 
promises, representations, negotiations, statements and/or understandings of the Parties.
i 11. Counterparts. This Agreement may be executed in counterparts, each Of which 
will be deemed to be an original copy of this Agreement and all of which, when taken together, 
will be deemed to constitute one and the same agreement.
IN WITNESS WHEREOF, I have hereunder set my hand this day of
2026.
SUBSCRIBED AND SWORN to before me this^ day of 
2026 by
Beverly Tyson. 
/ 
^
Not^ Public//
My Commission Expires
I
3.6. ZoZ-q
KIMBERLY A. LANK
o'Arizona
MARICOPA COUNTY 
y Commission # 678858 
Expires January 26, 2029
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Contract No. 2026-113-COS
CITY OF SCOTTSDALE, an Arizona 
Municipal Corporation
By:
Lisa Borowsky, Mayor
Dated:
ATTEST:
Ben Lane, City Clerk 
Dated:___________
APPROVED AS TO FORM- 
OFFICE OF THE CITY ATTORNEY
!ruis E^antaellarCuy Attorney
By; Lori S. Davis, Chief Deputy City Attorney
Dated:
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