Agenda 12/11/2018 Item #16K 612/11/2018
EXECUTIVE SUMMARY
Recommendation to approve and authorize the Chairman to execute a Settlement Agreement and
Mutual General Release with Hannula Landscape & Irrigation, Inc., in the amount of $28,0000,
concerning a payment dispute arising under ITB No. 16-6537R, the “Annual Contract for
Landscape Maintenance,” for work performed by Hannula between March 28, 2017 and May 2,
2017.
OBJECTIVE: Recommendation to approve the attached proposed Settlement Agreement and Mutual
General Release (the “Settlement Agreement”) for the total sum of $28,000.00 and authorize the
Chairman to execute that Agreement.
CONSIDERATIONS: On April 26, 2016 (Agenda Item 16.A.24), the Board awarded ITB No. 16-
6537R, its “Annual Contract for Landscape Maintenance” for Growth Management Road Maintenance
and Parks and Recreational divisions to Hannula Landscaping & Irrigation, Inc. (“Hannula”), as a primary
contractor, for specific maintenance areas along County roads. The landscape maintenance work under
this award generally includes mowing, edging, street cleaning, median weeding, general site trimming
and pruning of trees, trash removal and other similar landscape maintenance related tasks.
A payment dispute arose between Hannula and the County over landscape maintenance work performed
along Livingston Road during the period March 28, 2017 through May 2, 2017; which work is more fully
described in Exhibit “A” to the attached Settlement Agreement. This dispute generally arises as the
result of deficiencies by both parties to: administer the award as required by the terms of ITB No. 16-
6537R and the County’s incorporated standard terms and conditions, adequately document the work
performed (including exact location references, accurate descriptions of services and accountings of th e
completed work), and to conduct follow-up inspections to confirm that identified tasks were completed by
the contractor.
Examples of some of these deficiencies by the parties include:
Hannula failed to email weekly work schedules to the County’s Proje ct Manager no later than
7:00 a.m. on the Friday morning before the upcoming week as required in Section 12 of Invitation
to Bid # 16-6537R, so that the County landscape inspector could arrange to confirm the
completion of the identified work tasks during the upcoming week.
County staff determined that the sabal palms claimed to have been pruned by Hannula exceeds
the actual number of sabal palms counted and verified from as-built installation plans on
Livingston Road-Hannula claims it pruned 1,229 palms when only 1,184 palms existed before
Hurricane Irma and when the work was requested by the County. Although, that discrepancy
could have resulted due to a mistake, such as a redundant calculation while working at the same
location over a period of consecutive work days.
Hannula’s Landscape Grounds Maintenance Reports blended the “maintenance tasks” (general
site trimming, trash removal, street cleaning) required under the agreement with the “Additional
Services” for sabal palm pruning, a distinctly different billed task. The sabal palm pruning
should have been billed separately from the maintenance services to establish an accurate count
of man-hours expended to compete that work.
Although Hannula managed to email contemporaneous work sheets after it purportedly
completed pruning the palms, the County’s staff inspector for this project neglected to confirm
16.K.6
Packet Pg. 3120
12/11/2018
the completion for all of the work, notwithstanding that the confirmation could have been
successfully confirmed up to six (6) months after the pruning occurred, nor did County staff
follow up for additional information if it had questions as to the specific location where Hannula
completed the landscape work or why the work was billed as invoiced.
Hannula’s Invoice No. 22586R bills the County $42,030.00 for the landscape maintenance work it
claimed it completed. County staff calculated a baseline average man-hour required to prune sabal palms
by using the County’s as-built sabal palm quantities on Livingston Road, which amounted to
approximately 1.3 average man-hours to trim each sabal palm. The County’s staff landscape inspector
working for the County during that period confirmed that 379 sabal palms were pruned, which when
multiplied by 1.3 man-hours per palm, amounts to 492.7 man-hours. After applying the $45.00 hourly
billing rate for such work, County staff calculated an amount owed of $22,171.50 (based only on the work
it inspected).
Following further discussions with Hannula’s attorney, Hannula agreed to reduce its bill by $14,030.00
by proposing to settle all claims related to Invoice No. 22586R for $28,000. In making that offer,
Hannula does not admit that its invoice is inaccurate or that the landscape services billed were not
completed. Because Hannula provided contemporaneous notice to County staff after each pruning
service, which would have allowed County staff to confirm the completion of the work or follow-up with
the contractor regarding performance but did not (and could have inspected/confirmed completion of the
work for up to six (6) months from the date of receiving notice), it is the opinion of the County Attorney’s
office’s that it is in the best interests of the Collier County taxpayers to accept the settlement offer.
Accepting the settlement offer avoids the possibility of Hannula prevailing in a higher amount, including
the possibility of recovering its costs, attorney’s fees and interest on any judgment, if it were to file a civil
action.
GROWTH MANAGEMENT IMPACT: None.
FISCAL IMPACT: Funding of $28,000.00, for services rendered is within the Road Maintenance
Division, Landscape Maintenance Operations, Unincorporated Area General Fund 111, cost center
163801.
RECOMMENDATION: For the Board of County Commissioners to approve and authorize the
Chairman to execute a Settlement Agreement and Mutual General Release with Hannula Landscape &
Irrigation, Inc., concerning a payment dispute arising under ITB No. 16-6537R, the “Annual Contract for
Landscape Maintenance,” in the amount of $28,000.
PREPARED BY: Scott R. Teach, Deputy County Attorney
ATTACHMENT(S)
1. Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (PDF)
16.K.6
Packet Pg. 3121
12/11/2018
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.K.6
Doc ID: 7474
Item Summary: Recommendation to approve and authorize the Chairman to execute a Settlement
Agreement and Mutual General Release with Hannula Landscape & Irrigation, Inc., in the amount of
$28,0000, concerning a payment dispute arising under ITB No. 16-6537R, the “Annual Contract for
Landscape Maintenance,” for work performed by Hannula between March 28, 2017 and May 2, 2017.
Meeting Date: 12/11/2018
Prepared by:
Title: Legal Office Administrator – County Attorney's Office
Name: Debbie Allen
11/30/2018 12:10 PM
Submitted by:
Title: County Attorney – County Attorney's Office
Name: Jeffrey A. Klatzkow
11/30/2018 12:10 PM
Approved By:
Review:
County Attorney's Office Scott Teach Level 2 Attorney Review Completed 11/30/2018 1:23 PM
Office of Management and Budget Valerie Fleming Level 3 OMB Gatekeeper Review Completed 11/30/2018 1:47 PM
Budget and Management Office Mark Isackson Additional Reviewer Completed 11/30/2018 2:08 PM
County Attorney's Office Emily Pepin CAO Preview Completed 12/03/2018 9:48 AM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 12/03/2018 10:03 AM
County Manager's Office Leo E. Ochs Level 4 County Manager Review Completed 12/03/2018 11:07 AM
Board of County Commissioners MaryJo Brock Meeting Pending 12/11/2018 9:00 AM
16.K.6
Packet Pg. 3122
SETTLEMENT AGREEMENT AI\D MUTUAL GEI\TERAL RELEASE
This Settlement Agreement and Mufual General Release ("Agreement") covers all
understandings between HANNULA LANDSCAPING & IRRIGATION, INC. (herein referred to
as "HANN[-ILA," a reference that includes each and every ofEcer, director, present and former
employee, agent, parent corporation or subsidiary, committee, affrliate and division, their
successors, assigns, beneficiaries, selvants, legal representatives, administrators, fiduciaries,
insurers, and heirs, both in their representative and individual capacities) and Collier County,
Florida, a subdivision of the State of Florida (herein referred to as "COLLIER," a reference that
includes each and every Commissioner, its managers, directors, administrators, present and former
employees, agents, departrnents and divisions, and their successors, assigns, beneficiaries,
servants, legal representatives, fiduciaries, insurers, and heirs, past and present, both in their
representative and individual capacities).
WITI\TESSETH
WHEREAS, on April 26,2016, COLLIER awarded HANNULA ITB No. 16-6537& the
"Annual Contract for Landscape Maintenance," as a primary vendor to provide landscaping
services along an assigned geographic portion of County roadways, right-of-way(s) and other
properties that includes mowing, edging, street cleaning, median weeding, general site trimming,
trash removal and other similar landscape maintenance related tasks (the "landscape maintenance
work"); and
WHEREAS, HANNULA submitted Invoice Number 22586R and related supporting
documentation for the landscape maintenance work purportedly provided during the period
between March 28,2017 and May 2,2017, a copy of which is attached hereto as Exhibit "A;" and
WHEREAS, a dispute arose between HANNULA and COLLIER concerning the actual
work performed and the appropriate payment for the services provided by HANNULA; and
WHEREAS, COLLIER and HANNULA, without admitting any liability or fault by either
ofthem, now seek to resolve all disputes because both parties recognize the costs and uncertainties
of litigation should they remain unable to resolve this dispute; and
WHEREAS, COLLIER and HANNULA intend through this Agreement to resolve all
claims that have been asserted or that could have been asserted by either party that arise from, or
refer or relate in any way, whether directly or indirectly, to HANNULA'S Invoice Number 22586R
and those services identified in Exhibit *A."
@
16.K.6.a
Packet Pg. 3123 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
NOW, THEREFORE, in consideration of the mutual covenants, promises and
considerations set forth in this Agreement, the sufficiency of which is hereby acknowledged, and
with the intent to be legally bound, COLLIER and HANNULA mutually agree to the following:
1. COLLIER and HANNULA agreed to adopt and incorporate the foregoing recitals,
sometimes referred to as'\uhereas clauseso'by reference into this Agreement.
2. For and in consideration of the promises made by FIANNULA in Paragraph 3 of this
Agreement, COLLIER agrees to pay HANNULA the total lump sum of Twenty-Eight
Thousand dollars ($28,000) in the form of an ACH deposit to HANNULA, and such
other good and valuable consideration, within ten (10) days after the full execution of
this Agreement by both parties. HANNULA understands and agrees that these monies
will be paid to them upon satisfaction ofthe conditions set forth herein, with each party
bearing its own costs and attorney's fees in this payment dispute.
3. For and in consideration of the promises outlined in Paragraph2 of this Agreement,
HANNULA agrees as follows:
a. To settle any and all claims and actions of any nature whatsoever between
HANNULA and COLLIE& and to release, acquit and forever discharge
COLLIER of and from all and any manner of actions, causes of action, suits,
rights to attorney's fees, debts, claims, and demands whatsoever in law or equity
by reason of any matter, cause orthing whatsoever, and particularly, but without
limitation of the foregoing general terms, by reason of any claims or action
arising from Invoice Number 22586R (and the landscape maintenance work
memorialized therein) submitted by HANNULA to COLLIE& a copy of which
is attached as Exhibit "A." Further, without limitation, IIANNULA waives
and releases all similar rights and claims under all federal, State and local
provisions and all other statutory and common law causes of action, including
breach of contract, negligence, negligent misrepresentation, quantum meruit,
promissory estoppel, as well as all slaims for attomey's fees and costs under
any statute, rule, common law cause of action or otherwise, by reason of any
conduct, matter, cause, act or omission arising out of or relating in any way to
the invoicing attached as Exhibit "A," existing at any time prior to this
Agreement, which HANNT LA may have had or may have now, whether
known or unknown, suspected or unsuspected, including claims asserted, or in
any otherjurisdiction or forum whatsoever.
b. To not sue or make any claims against or involving COLLIER for any reason
arising from Exhibit o'A" and the landscape maintenance work occurring from
the beginning of time through the date HANNULA executes this Agreement.
16.K.6.a
Packet Pg. 3124 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
4.
c. Thatthis settlement is made and accepted in compromise of a disputed payment
claim and does not, and shall not be construed to, constitute an admission by
COLLIER of any liability, violation of any federal, State, or local statute or
regulation, or any violation of HANNULA's rights or that COLLIER owed or
owes any duty owed to HANNULA.
In consideration of the parties' sefflement of this payment dispute, COLLIER hereby
remises, releases, and forever discharges HANNULA ofand from all manner of actions
and causes of action which could have been, or should have been, asserted in the
payment dispute between HANNNULA and COLLIER arising as a result of Invoice
Number 22586R and the landscape maintenance work set forth in attached Exhibit "A."
HANNULA shall not be deemed to have admiued liability, which it expressly denies,
and the parties understand and agree that COLLIER is providing this release to
HANNULA in full accord and satisfaction of a disputed claim.
COLLIER agrees that a breach of this Agreement may result in irreparable and
continuing damage to HANNULA for which there will be no adequate remedy at law.
In the event of a breach of any provision of this Agreement by COLLIER, HANNULA
shall immediately be entitled to pursue all remedies it may have against COLLIER in
any court of competent jurisdiction by specific performance, injunction, or such other
remedies and relief as may be available, regardless of any contrary provision of this
Agreement. COLLIER agrees that venue for any litigation under this Agreement shall
be in Collier County, Florida.
HANNULA acknowledges that, before sigmng this Agreement, consisting of six (6)
pages in total (not including the attached Exhibit "A"), HANNULA has read it, has
been given a reasonable and sufficient period within which to consider it, and fully
understands its terms, content and eflect.
HANNULA and COLLIER represent and agree that they have participated equally in
the negotiation of the terms and provisions set forth in this Agreement and that no
presumption or interference shall apply against either party hereto in its construction.
HANNULA and COLLIER agree and acknowledge that, in the event a court of
competent jurisdiction finds that any portion of this Agreement is invalid, the other
provision shall remain in fuIly force and effect.
9. It is further understood, acknowledged and agreed by HANNULA and COLLIER that
the terms of this Agreement are contractual and not a mere recital, that the Agreement
contains the entire agreement of the parties hereto and that there are no agreements,
understandings or representations made by I{ANNULA or COLLIER, except as
expressly stated herein. This Agreement supersedes all prior agreements and
5.
6.
7.
16.K.6.a
Packet Pg. 3125 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
understandings between HANNULA and COLLIER. No cancellation, modification,
amendment, deletion, addition, or other changes in this Agreement or any provision
hereofor any right herein provided shall be effective for any purpose unless specifically
set forth in a subsequent written agreement signed by authorized representatives of
HANNULA and COLLIER.
10. HANNULA and COLLIER agree that this Agreement is entered into knowingly and
voluntarily, after having the opportunity to fully discuss it with an attorney.
IN WITNESS WHEREOF, HANNULA and COLLIER have executed this
SETTLEMENT AGREEMENT AND MUTUAL GENERAL RELEASE on the below indicated
dates.
SIGNATURE PAGE TO FOLLOW
16.K.6.a
Packet Pg. 3126 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
ATTEST:
Clerk of the Circuit Court and
Ex-Officio Clerk of the Board of
County Commissioners of Collier
County, Florida
BY:
Crystal K. Kinzel
Scott R. Teach, Deputy County Attorney
BOARD OF COMMISSIONERS OF
COLLIER COUNTY, FLORIDA
BY:
ANDY SOLIS, CHAIRMAN
16.K.6.a
Packet Pg. 3127 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
I
i
HANNI.'I.A I,AITIDSCAPINO
& IRruOATION.INC.
IlaEd: Ncva.YrLarg .:l S,')nr'l'
STA'IE OF FIORIDA )
COLINTY oF Sgl*trRte)
hintsd I.Iue ofNMy Public
16.K.6.a
Packet Pg. 3128 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Exhibit A
16.K.6.a
Packet Pg. 3129 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Hannula Landscaping & Irrigation, Inc.
?050 Pennsylvania Sreet fnvoice
:0 X'Xmne-W
r----
fH n N Ntrf6) Fi-'- -ii:-'=-:';L i3 e i 2
I r-Al.roscal,tt.lc a nRnaroa\r nn I (""/ aJ /-7iluo
:
Clerk's Finelee Department
3299 'l'anriarni l rail E. $Tf ?00
Naplcs, fL 34 I 12-5149
16.K.6.a
Packet Pg. 3130 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Palm Trirnmin* Work Sheets
5-Men Trim Palms
2 Men Trim Plams
otalTrirn Planrs
Me n TrashlStreetClean/Prune Trees
5 Men Trim Palms
Men Trim Palms
SubtotalTrim Palms
Men Trash/Street Clean Prune Shrubs
Total Hours =
5 Men Trim Plams
Men Trim Palms
talTrim Palms
2 Men Trash/Street Clean/Prune Trees
5 Men Trim Palms
2 Men Trim Palms
2 Men Trash/StreeCleanfPrune Trees
5 Men Trim Palms
1 Man Trim Palms
otElTrim Palms
1 Man Trash/Street Clean
5 Men Trlm Palms
1 Man Trim Palms
SubtotalTrim Palms
1 Man Trash/Street Clean Prune Trees
otal Hours =
WORK AREA: LlVltrI6ST0N ft0AD
Date Of
Worksheet
3l2el2}fl
4/UzAy
4/3/20.77
,150.00
52,160.00
$2.160.00
777,3A
s1,990.00
16.K.6.a
Packet Pg. 3131 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
5 Men Trim Palms
lTrim Palms
1 Man Trash/Street Clean
Total Hours -
l Man Trim Palms
lTrim Palms
1 Man Trash/Street Clean Prune Trees
5 Men Trim Palms
1 Man Trim Palms
btotalTrim Palms
2 Men Trash/Street Clean Prune Trees
5 Men Trim Palms
Men Trim Palms
btotalTrim Palms
2 Men Trash/Street Clean/ Prune Trees
SubtotalTrinr palm!
7 Men Trim Palms
7 Men Street cleanfirim Shrubs & Prune Trees
7 Men Trim Palms
ubiotalTrim Palnrs
Men Trash/Street Clean Prune Trees & Shrubs
6 Men Trim Palms
btotaltrim Palms
1 Man Trash/Street Clean Prune Trees
4/6/2017
4/7lzAfi
4-LA-U
4/xil2Afi
tzl2017
4h3120t7
s1,890.00
s1,890.00
t1,867.50
$2,160.00
s720.00
5630.00
$945.00
16.K.6.a
Packet Pg. 3132 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
4l$/2a77
4/17/2OL7
4/$12afi
4/28/zAfl
4/29121fi
l Man Trim Palms
SubtotalTrim Palms
1 Man lrash/ Street Clean
5 Men Trim Palms
l Man Trim Palms
1 Man TrashlStreet Clean Prune Trees
1 Man Trim Palms
SubtotalTrirn Palms
1 Man Trash/Street Clean Prune Trees
5 Men Trim Palms
1 Man Trim Palms
1 Man Trash/Street Clean/ Prune Trees
5 Men Trlm Palms
I Man Trim Palms
1 Man Trash/Steet Clean Prune Trees
9 Men Trim Palms
5ubtolalTrim Palrns
Men Trash/Street Clean Prune Trees & Shrubs
otal Hours =
7 Men Trim Palms
1 Man Trim Palms
talTrim palms
I Man TrashfPrune Trees
s2.340.00
$1,f,80.00
$1,e80.00
$t,62o.oo
1,575.00
Ll2$fi
s2,250.00
16.K.6.a
Packet Pg. 3133 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Men Trim Palms
SubtotalTrinr Palms
1 Man Trash/Street Clean Prune Trees
Total Hours *
Total Palms Trinrmed , 7,229 TotalCost=942
16.K.6.a
Packet Pg. 3134 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
,TMLlrta:
Jrrre.'rg S'i#*S"
-rt']. . .r \isb\
Le nd acape G rqrrds Hdremrp ..*oortTlfr.*,lJf
-_ Ihrl
SlbCondltlqu; Ralry // $unny / Wndy
hmagrl Whd / Raln /Artcmobile Aootdent/Var&llsm i Thfr
RaF/Gdhna
Chsmlcal !{arns &tr/Cethrk
Blond
4i
16.K.6.a
Packet Pg. 3135 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landrcapr Groundr Hdnbnrncr Btnort.
Pmrsoi Rhmr:
Sllo0otdltlaru: Ralny // Sunny / \tYlndy
'&$ , ${ffilr
r.tr (*;tlfie.i
i$r#
Dmrgim: Wlnd 1 f{aln I Automob$g Aoddsr* I VandElism /
Plne $traur
EunalSptur Blard
16.K.6.a
Packet Pg. 3136 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landecape Gruundr talnlrnanoe Rcport
Pmlect ldrms:
. Sfu So*dltlona; Ralny // Sunny, Wlndy
%%1g.g'*##nuan: 4iffffiffimffiiffi*'i ry, dr;,y& ii.rr
#rn
Damrgec: Wlnd / Ratn / A.rbmobila AccUsnt I Vandalhm / Thefr
16.K.6.a
Packet Pg. 3137 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Damagcr; WlDd , Rain / Automobllo Asddonr / Vandaltrrn / Thaff
Landccaps Gmundc iidnbnirm nrmrt
Pn{rct f{arnr;
$lla Condltlonr: Ralrry // Sunny / Wlndy
loqdbn:_-..._._
rlr: I,--'4-**ffimHr- inr€.n i;", i:ifi(i.
i's*
Tlroo Chsfnhd Namo n*lAdloru 0t .
16.K.6.a
Packet Pg. 3138 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landrcapo Grcund* ttalnbnanco neport
Profedllaml
SttoCondlilonr: RalrV /
Dasagsr: lrUirld, Raln,
{Rutndup}
(Hana;
Ckenlng
h o,;io*. {r{ ?. .}X e,ii_**r --',-''-'':'":-.*j ($.i-'Baah ]*afilurance Func&ru
16.K.6.a
Packet Pg. 3139 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landacape Gmundr t*aMrmroa
Pror€ct Haraol
Slta Gondltlsnr: Rakry /I Sunry, W,rdy
Darnagec: Wlnd / Rein /Artomobila Aocident / Vsnddbm / Thffi
Cltfnlcd l-lryrns tsp0pl Gdlsng
Clrmlcal Namo Fbb/Galhng
Pffi.e-{
@
16.K.6.a
Packet Pg. 3140 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
FroJect l{amr:
8!lr Goardltbns;/ Sunny / Windy
Deaage: llYlnd / Rdn I AubmoHle AccHont / Vandalie,n / Thatl Qm*^ eqh*&
rff:
16.K.6.a
Packet Pg. 3141 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
tandecapc Gnounds f,tatr*Ensne -&b
Proric( hlamr:
$ltr Condltbnrl Ra&ry // $unrry / Wlndy
Ilanqrr: Wind I Rdn / Au&noblle Aoddent / Vandalirm / Thd
(Roundup)
(Handl
Cleaflhg
Chomhd NemE SsklQen*
&
$te$,
s;n-t
16.K.6.a
Packet Pg. 3142 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landrcapr Groundc Hdn&nsnc. nsport
erlolrct llamo:
$l!rCsndllbncl / Sunrry I Whdy
Oemagr: Wnd / Ratn / Artomobite Acddsnt / Vands[8m / Thsfl
ChaFl+pl.Ngma Ratpl6gllgrr
e.*, ,5:Qf?,- -
t *, * -,an', 1g 5.p,.*;1p:i
-'
r"^--'si"*
a*.| {14*s- i
| ''t--"...,--' '
Tpa
urf
Barlc itlalntrnrnor Funotlui
16.K.6.a
Packet Pg. 3143 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Lan&cap Grurnd* ffdribnanoo
Ptar.ct l{emal
$t$a Cordlflono: Rainy I / $unny I Wlndy
&magc: WkH / Rstn I &tbmoblte Accidenl / Vandallrm I Thsft
lapk trdntrrxnor Punr*lcnu
(Ranndup)
(Fhnd)
Cleanlng
6b.)
9!gni*al l.lama Ba&{Qailons
Chqrniqnll&me R#/Gaflons
16.K.6.a
Packet Pg. 3144 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Land*c*p* Grq.rndo f,klntrnrnea Repcrt j-:=:.. ,e.IEfu
Ptorr.tfllarm:
Sltt Condlttronr:I &rrny / Wlndy
&mago*: Wind / Raln / Albmoblta Aooident / Vandalhm , Thsft
Hdnhrans fur bm
(tuundup)
(Hand)
Cleanlng
efianlcal i{ams W/Sallong
Ctxmhd Xafng BdBl.Gallons
l.oos,tlon:
16.K.6.a
Packet Pg. 3145 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Demts: Wlnd / Reln, Automooih Acddenr / Vanclalisrp / Tt reil
Prqpct ${rmo:
$lbCqndltlonrr / Sunny / Wlndy
{noundup}
(Hsnd)
ClrmlrU
Chimlcd tlsms RsE/Gsfiom
Tm CtramhalNrme Iiug m
Fina Srary
Eucalpsrs Blood
16.K.6.a
Packet Pg. 3146 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Lendscapc Grounds lialntrnancc flreg.*1ffils"t'.H$;
Frofcct ldamo:
$ita$ondHbm: Rdny / $unny / Wlndy
Damqac: Wind/ ttatn /AutomoblleArpldent/ Vandathm rl.h*lrnangVhx-s
Swlc &{dl$mare Fundomr PrunlnuJfdmnrbro ffiuhh k;
sntal Grms* tgl
ou
rash
ng (Rulndup)
ne 0land)
Claanhgtl
16.K.6.a
Packet Pg. 3147 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landrcape Broundr ilalnhmncc Report
kd.ot l{rmr:
Stt Condltbm: Relrry I / Sunny, WMy
Damegre : Vlrhd I Ra|n I Aubrnoblle Acrgdenl / Vandallsm I Thdt
!--4\1
1 J-.* ". :\.. i d.- ..
8rrb ffialntsnance Fundlo*u Pnrnlrrltlmndns llulofr
(Rrundup)
{}land)
Oceilng
Itrae
Phe Sbary
Br@;Src 8&nd
Ctmresr
PfnNu6eb
Offrtr
0th6r
Oths
16.K.6.a
Packet Pg. 3148 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Pojrct l{rrnu:
Darnagca; Wlnd / Rain / AutunoDllo /tcddont / Vanddlsm / Thsft
Eeda ffdntarnca Functlotr Prunlns lTrlmmlm Hulctr
TYoeit=*,
ieucatyptur aenO
iqrr"o
iPlna Nuggeb
lOllter
,&Olhcr
(Rotmery)
(Hand)
Claailrg
Shm>NsEs ffib/Salone
16.K.6.a
Packet Pg. 3149 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
PrcJert ila.nel
9lts0ondlflona Rainy /I &rnny I UIindy
Rab/Gdons
TrrEh Pldr
kbrle
E Debrb
Damagr: Wnd / Ratn / Aubmobfl,e Acddent / Vandaltrm / Theft
out Y:Vt
_try*'qg t{nf_,-{,
16.K.6.a
Packet Pg. 3150 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
l"endrcapo Groundr ilrlnbnancrr ng,brt
;.rt--.._
Pnrfact ilame:
$frcondldom: Rairy / Cloudy / Sunrry / Wndy
Damagcl Whd , Rsln I Arbmobila Accjt{ent / Vandallunt i fhatt
cmmlelrysms ffsu,/Sdlffiu
Tlmr lnr &. p A Ttmr OuB.g*effibn+r,
l.lomxl Dobris
@, H*rri*
ft_fi
Type
rlrf
[rd)ris
16.K.6.a
Packet Pg. 3151 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula)
Landacape Grcum*r ftisrnbnasrm ygm
Proloct l{errr,.
3ltr (bndfflom: Ralny // Sunny Mlndy
Dalrgac: Wind / Rdn / Artomobltc Acuident lVandalbm lTtEft
l.odon:
Tlnnr ln: 6 ^.r- r<l-.e, .ir!F$||':{
Tlamin: l,:@ flmsOur; &1. g-f
:.:..f;i_..*ffi?.'ffi..!.";t$q-.F + ,iffi1-ffiffi(f#EHffi ii; 3 ieJ..,*.;cr tS.fX
fr
Chsmlcal Nama RatE/,c#lonc
rE (Romdup)
rU(Hand)
Clsanlng
16.K.6.a
Packet Pg. 3152 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landrcape Gmrndr Hdntanrnce Aspot{
i-E
Prolecg ffamu
$itr Gondttlorr: Ralny // Sunny I t4llndy
Cft$nH ilmB RdbrGerp
Rata/Sallcas
Locstt
ouk__ y; {.f_
mg{@Wfre*
{j-I}
Itao
urf
D{nago!; Wlnd / Raln /Aubmobth Acctdent /Vandallsm lTheft
Eerlc tdnhnnct Funrdom
ng (Roundup)
ng (l{and)
Cleaning
'alme ^e g
rooS
16.K.6.a
Packet Pg. 3153 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Landaw p* 6reund* Mafrr&**neq Rsport
-,lr
Proid i{xnrr:
$lbeondltlsru;: Rainy I / $unny / Windy
Samqrx: Wkd I Ra,n / Auhrnobih Amidont I Varxdafiem I
Burlc Halnhr*rm Funcffona
SlmuumlIama eeJ-Aallsns
Qhemical-l{arnE SStgIGslbns
Tw,e
: l0 men €?.4eW..9
eedlng (Roundup)
x&.?'ffitmffi:ffi-
16.K.6.a
Packet Pg. 3154 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Pn rsct g{eilEl
$lla &oldltlonr: Ratny I I Sunny / Windy
Damrgra: Wlnd / Raln / Automoblle Accidert / Vandaliam / Thot SffiWWSffiW: -lmwg?h^es
Easlc i*aln$n il&o Func*bnr
(Rrundup)
(!.knd)
Cleaning
Iwq
uff
ehpmffilhlryno me&-/gqthm
Eqbl Qalbm
su
Stalv
16.K.6.a
Packet Pg. 3155 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
t"ar&cxpo #r*undx Wslntrynxlrns ruWofi
T
Fmlerf flmrna:
8lb Condttlor*: Rainy /
Ormryeal Wind / Rain / Aubmobib Acddent / Vardalism / ThEft q$E.slsffisi il#pBr
rtnwtr;. _,*: 4! *. ,Trms out:
-,a.(:,)kffi.s\.
Eado i$alnbnrnoe Fundon:
(Roundup)
tHand)
Cbanlrry
Rqlg/Cgllorlc
r,,{SMm.,*.'luue thembqlNam*
'--- *--Wffi1ffiffi$fLff--
16.K.6.a
Packet Pg. 3156 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General
Lnndxcrpe Grounde ffi a$ntsnqnr* flsport
Pn{{,r{ i'3arns:
$lta Condltlons; Rsiny I I Sunny / Wlrdy Tlrllg tfl: d , oe Tlmc &rt:d'ed
Damagoc: Wnd I Rain I Attsnobfie Ascidsnt / Vandalhm / Thsfr ryF.rygrDBn$ry$',4 ?, ?$-
k(: b
Chernlcal i*,lamo f{etslGalbm
TJoo 9JnmMl !{qno Rst€/ Gallom Tvpr. . "St-Emieal f{nrfe-.ff*q- Otv
lnmctc'ido
FurglcHe
llsrblcl&
- : , ffiscHtlrrk$.doFtfoRKFEXfoRifiH0:*ww
*ffi
gu
Stratv
16.K.6.a
Packet Pg. 3157 Attachment: Proposed Settlement Agreement and Mutual General Release (signed by Hannula) (7474 : Settlement Agreement Mutual General