Agenda 03/22/2022 Item #16K5 (Mediated Settlement Agreement - Tri-Party Construction Agreement)03/22/2022
EXECUTIVE SUMMARY
Recommendation to approve: (1) a Mediated Settlement Agreement and Mutual Release resulting
from the pre-suit dispute resolution process in the Tri-Party Construction Agreement between
WPM-Southern, LLC, the City of Naples, Florida, Collier County, Florida, and the design engineer
on the Project, Q. Grady Minor & Associates, P.A., (2) an Interlocal Agreement acknowledging the
City’s relinquishment of $300,000 in funds the County had appropriated to reimburse the City for
construction costs on the West Goodlette-Frank Road Area Joint Stormwater-Sewer Project, (3)
the attached budget amendment, and (4) to authorize the Chairman to sign the attached
agreements.
_____________________________________________________________________________________
OBJECTIVE: To approve the attached Mediated Settlement Agreement (the “Settlement”) resulting
from the pre-suit dispute resolution process provided in the Tri-Party Construction Agreement between
WPM-Southern, LLC (the “Contractor”), the City of Naples, Florida (the “City”), Collier County, Florida
(the “County”), and Q. Grady Minor & Associates, P.A. (the “Design Engineer”) (collectively, the
“Parties”), a separate Interlocal Agreement between the City and County acknowledging the City’s
relinquishment of previously-appropriated County funds as part of the West Goodlette-Frank Road Area
Joint Stormwater-Sewer Project (the “Project”), and to approve the attached requested budget
amendment.
CONSIDERATIONS:
Summary of Settlement
The proposed Settlement represents the Parties’ recommended compromise of disputed monetary claims
raised by the Contractor in the amount of $2,249,999.31, and includes a process to correct existing alleged
Contractor deficiencies on the Project. The recommended Settlement i nvolves payment to the Contractor
as follows: the Design Engineer agrees to pay to the Contractor $175,000.00 and the County agrees to pay
the Contractor $525,000.00. Separately, the City is agreeing to forego reimbursement by the County of
$300,000.00 in funds the County previously appropriated towards the City’s general construction costs on
the Project. The Contractor’s bid on this Project was $1,074,672.50 lower than the second lowest bid, so
notwithstanding any unexpected issues, the Settlement will resolve all existing monetary claims and allow
the Project to still close out well below the second lowest bid. The County’s longtime construction law
outside counsel, Paul Ullom of Carlton Fields, and its scheduling expert, recommend the proposed
$700,000.00 settlement as within the recommended range to favorably resolve this dispute.
Factual Background
The Project
On September 14, 2015, the County formally requested the City’s joint participation in affecting a
comprehensive solution to provide sanitary sewer and stormwater improvements in an area west of
Goodlette-Frank Road and east of US-41 that was un-sewered and historically experienced significant
flooding. On September 27, 2016, the County approved an Interlocal Agreement with the City to
commence a joint project to design and construct stormwater and sanitary sewer facilities for the Project.
That Agreement was subsequently amended by the County and City to provide further specificity of their
respective duties and responsibilities on April 24, 2018.
The engineering plans for the Project were prepared by Q. Grady Minor & Associates, P.A. in response to
a Request for Proposals, and a contract was awarded on July 11, 2017.
The County advertised Invitation to Bid No. 18-7322 to solicit for the construction of all elements of the
16.K.5
Packet Pg. 1484
03/22/2022
Project (both the City’s sewer portion and the Count’s stormwater portion), which included some shared
costs primarily related to the road construction (the “Shared Costs”). The Contractor’s low bid of
$13,353,480.00 was approximately $1,074,672.50 lower than the second lowest responsive bidder, and
approximately 9% less than the Design Engineer’s opinion of probable cost. The total contract amount,
including a $1,016,520.00 contingency for unanticipated underground conditions, is $14,370,000. That
total contract sum included an $88,761.00 mathematical error in the public agencies’ favor, which the
Contractor agreed to accept.
The County’s stormwater portion of the contract amount, including the Shared Costs, is $6,715,239. The
City’s sewer portion of the contract amount, including the Shared Costs, is $7,654,761. On July 10, 2018
(Agenda Item 11G), the County approved the contract with the Contractor contingent on approval by the
City of an Assessment to fund the Project within 120 days of the recommended award.
At the Board’s July 10, 2018 meeting, it also accepted and approved County staff’s recommendation that
the County assume a portion of the City’s engineering design costs in a sum not to exceed $313,000.00,
and to appropriate an additional $300,000.00 of County funds to subsidize a portion of the City’s general
construction costs for this joint project. During the course of the Project, the County satisfied its agreed
upon portion of the City’s engineering design costs, but the funds the County appropriated for the City’s
general construction costs remain outstanding and have not been reimbursed by the County to the City.
The Dispute
On or about October 13, 2020, the Contractor wrote both County and City staff seeking to renegotiate unit
prices for several line items of materials that had been extremely underestimated (in excess of 25% and in
some instances much higher) by the Design Engineer. Although the Agreement allows the discretion to
re-negotiate unit prices where the actual quantities exceed 125% at the time of bid, there is no obligation
to do so.
At around the same time, the Contractor also claims the Design Engineer sent an email that stayed the
Project until a formal change order was approved memorializing an increase to the unit prices of the
underestimated materials. The County disputes the Contractor’s characterization of that email, but it
creates an issue of fact as to the Contractor’s claim that its work on the Project was actively interrupted by
the alleged stay thereby entitling it to extra days and monetary damages.
The Project also intermittently experienced payment flow issues. At times those issues were exacerbated
by the Contractor’s failure to submit required back-up documentation with its payment application, but
those issues could have been partially assuaged had County staff timely sought partial payment where
back-up documents had been submitted. Without admitting any culpability, this issue also impacted the
Project.
Ultimately, because of payment dispute issues, the Contractor stopped working on the Project entirely on
July 9, 2021, claiming that the Project was substantially complete, and that very few tasks remained to
conclude the work. As of today’s date, the project (not including correction of any existing deficiencies)
is approximately 96% complete. Since that date, the parties actively engaged in efforts in an attempt to
resolve the dispute and keep the Project moving forward to completion, eventually resulting in all day
mediation sessions on December 23, 2021, and February 4, 2022, which culminated in this recommended
Settlement.
The Details of the Claims and the Recommended Settlement
a. The Claims
During mediation, the Contractor’s claims consisted of :
16.K.5
Packet Pg. 1485
03/22/2022
1. A request for 257 days of additional contract time based upon five alleged events of delay.
2. An asserted monetary claim of $2,249,999.31 consisting of a $1,444,825.48 claim seeking
reimbursement for (a) mobilization and maintenance of traffic costs for the 257 day alleged
period of delay, and increased unit costs for underestimated quantities of stabilized
subgrade, limerock base, and asphalt, and (b) a $805,173.83 claim based on additional
inaccurate quantity estimates by the Design Engineer related to HDPE Pipe and other
related materials pertaining to the stormwater portion of the Project.
The County rejects the Contractor’s above claim for $805,173.83 because, among other reasons, it was
not timely asserted as required by the contract. Therefore, the monetary claim comes down to an analysis
of the Contractor’s remaining $1,444,825.48 claim for damages.
The remaining claim is based upon the Contractor’s allegation that it was interfered with and delayed in
completing the work over a non-consecutive period of 257 days. The Contractor’s $1,444,825.48 claim,
not including $144,352.50 in markup and bond expense, breaks down as follows:
• $404,723.60 Mobilization for 257 days at $1,574.80/day.
• $374,266.53 Maintenance of Traffic for 257 days at $1,456.29/day.
• $266,314.18 Increased Unit Cost of Stabilized Subgrade for all 50,534 SY used.
• $187,163.07 Increased Unit Cost of Limerock Base (6-inch) for all 42,239 SY used.
• $ 68,005.60 Increased Unit Cost of Asphalt (2.5 inch, 2 lifts) for all 40,240 SY used.
Outside counsel and staff’s recommendation for settlement, without admitting any liability, is roughly
based on recognizing approximately 144 days of delay resulting in additional mobilization and
maintenance of traffic costs of $436,476.46, and premium price increase adjustments to the unit cost of
the underestimated materials in excess of 100% of the bid schedule amounting to $157,049.45 (for a total
amount of $593,526.41). The recommendation to settle for $700,000.00 is also based upon the additional
costs that will be incurred in attorneys’ fees, professional consultants, and other costs such as electronic
discovery expenses should this matter proceed to litigation, as well as the inherent risks and uncertainty of
such litigation. If this dispute is not settled, the conservative cost estimate to litigate this case through
trial is approximately one million dollars ($1,000,000.00).
b. The Recommended Mediated Settlement Agreement
The attached Mediated Settlement Agreement proposes to settle the Contractor’s claims as follows:
1. In consideration of the full settlement and release of the Contractor’s claims, the
Design Engineer, and the County agree to pay to Contractor the amount of
$700,000.00, as follows:
a. Design Engineer $175,000.00
b. County $525,000.00
The City’s separate monetary contribution lies outside the Mediated Settlement
Agreement and is set forth in the attached Interlocal Agreement. As previously
discussed, the County agreed to appropriate $300,000.00 to reimburse the City for a
portion of its general construction costs on the Project. The Interlocal Agreement
provides that the City waives reimbursement of the $300,000.00, which can now be
directed towards settlement and represents a 57.14% share of the amount designated
paid by the County.
2. The Contractor agrees to remobilize its construction forces within ten (10) days after
16.K.5
Packet Pg. 1486
03/22/2022
its receipt of any portion of payment on its last two payment applications (including
any short payments), complete all remaining work under the contract, and correct
any defective, deficient, and/or incomplete work on the Project. The Settlement
includes a deficiency list of remaining work and a mechanism allowing an
independent third party engineer to resolve disputes if the parties are unable to agree
on whether work on the list requires correction or completion by the Contractor.
3. As part of the Settlement, the Contractor agrees to first make payment to any
subcontractors that may be owed any outstanding amount for performing work on
the Project. This provision is a material condition under the Settlement.
It is also worth noting that the County received grant funding in the amount of $800,000 from the South
Florida Water Management District / Big Cypress Basin for its stormwater construction on the Project. If
the recommended Settlement is not approved, it is unlikely that the Contractor would be willing to
independently remobilize and return to the work site to address the various remaining identified
deficiencies, resulting in further delay and inconvenience to the residents of the community. The net
result of the recommended Settlement is that this low bid contract will still cost substantially less than the
second lowest bid, even after payment of the Settlement proceeds. The r ecommendation to approve the
Mediated Settlement Agreement is based upon the favorable resolution arrived at by the parties and the
potential costs and always present risks associated with proceeding with litigation.
FISCAL IMPACT: A budget amendment in the amount of $ 525,000 is required to transfer funding
within the Stormwater Bond Fund (327) from Reserves to Project 60142 to cover the cost of the mediated
Settlement Agreement. The source of funding is stormwater bonds.
GROWTH MANAGEMENT IMPACT: There is no Growth Management Impact associated with this
Executive Summary.
LEGAL CONSIDERATIONS: The Mediation Settlement Agreement and Mutual Release has been
reviewed and approved by the Transportation Management Services Department staff, the County
Attorney’s Office, and the County’s outside counsel, Carlton Fields. In the event that the recommended
Settlement is not approved, the County can expect to incur significant additional costs associated with
future litigation including attorneys’ fees and retaining expert witnesses, and a positive result can never be
guaranteed with any degree of certainty. This Settlement is reasonable based on the totality of the
circumstances. The subject of this Settlement is a matter of potential future litigation a nd should not be
discussed pending Board action. This item is approved as to form and legality and requires majority vote
for Board approval. -SRT
RECOMMENDATION: Recommendation to approve the attached Mediated Settlement Agreement and
Mutual Release, Interlocal Agreement with the City of Naples, the attached budget amendment, and
authorize the Chairman to sign the attached agreements.
Prepared By: Scott R. Teach, Deputy County Attorney
ATTACHMENT(S)
1. Interlocal Agreement pdf 031422 srt (PDF)
2. Mediated Settlement Agreement 032222 Final (PDF)
16.K.5
Packet Pg. 1487
03/22/2022
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.5
Doc ID: 21696
Item Summary: Recommendation to approve: (1) a Mediated Settlement Agreement and Mutual
Release resulting from the pre-suit dispute resolution process in the Tri-Party Construction Agreement
between WPM-Southern, LLC, the City of Naples, Florida, Collier County, Florida, and the design
engineer on the Project, Q. Grady Minor & Associates, P.A., (2) an Interlocal Agreement acknowledging
the City’s relinquishment of $300,000 in funds the County had appropriated to reimburse the City for
construction costs on the West Goodlette-Frank Road Area Joint Stormwater-Sewer Project, (3) the
attached budget amendment, and (4) to authorize the Chairman to sign the attached agreements.
Meeting Date: 03/22/2022
Prepared by:
Title: – County Attorney's Office
Name: Madison Bird
03/14/2022 2:33 PM
Submitted by:
Title: County Attorney – County Attorney's Office
Name: Jeffrey A. Klatzkow
03/14/2022 2:33 PM
Approved By:
Review:
County Attorney's Office Scott Teach Level 2 Attorney Review Completed 03/15/2022 8:18 AM
Growth Management Department Trinity Scott Transportation Completed 03/16/2022 9:25 AM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 03/16/2022 9:42 AM
Office of Management and Budget Susan Usher Additional Reviewer Completed 03/16/2022 10:05 AM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 03/16/2022 10:14 AM
County Manager's Office Amy Patterson Level 4 County Manager Review Completed 03/16/2022 12:00 PM
Board of County Commissioners Geoffrey Willig Meeting Pending 03/22/2022 9:00 AM
16.K.5
Packet Pg. 1488
16.K.5.aPacket Pg. 1489Attachment: Interlocal Agreement pdf 031422 srt (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal Agreement)
16.K.5.aPacket Pg. 1490Attachment: Interlocal Agreement pdf 031422 srt (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal Agreement)
16.K.5.aPacket Pg. 1491Attachment: Interlocal Agreement pdf 031422 srt (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal Agreement)
16.K.5.aPacket Pg. 1492Attachment: Interlocal Agreement pdf 031422 srt (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal Agreement)
16.K.5.cPacket Pg. 1493Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1494Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1495Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1496Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1497Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1498Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1499Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1500Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1501Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1502Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1503Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1504Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1505Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1506Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1507Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1508Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1509Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1510Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1511Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1512Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1513Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1514Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1515Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1516Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1517Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1518Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1519Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1520Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1521Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1522Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1523Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1524Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1525Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1526Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1527Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1528Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1529Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1530Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1531Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1532Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1533Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1534Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1535Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1536Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1537Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1538Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1539Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1540Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1541Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1542Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1543Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1544Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1545Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1546Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1547Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1548Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1549Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1550Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1551Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1552Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1553Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1554Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1555Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1556Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1557Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1558Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1559Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1560Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1561Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1562Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1563Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1564Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1565Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1566Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1567Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1568Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1569Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1570Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1571Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1572Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1573Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1574Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1575Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1576Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1577Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1578Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1579Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1580Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1581Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1582Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1583Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1584Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1585Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1586Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1587Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1588Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1589Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1590Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1591Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1592Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1593Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1594Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1595Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1596Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1597Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1598Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1599Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1600Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1601Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1602Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1603Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1604Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1605Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1606Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1607Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1608Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1609Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1610Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1611Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1612Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1613Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1614Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1615Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1616Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1617Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1618Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1619Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1620Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1621Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1622Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1623Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1624Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1625Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1626Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1627Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1628Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal
16.K.5.cPacket Pg. 1629Attachment: Mediated Settlement Agreement 032222 Final (21696 : Mediated Settlement Agreement, Mutual Release and an Interlocal