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COMPROMISE SETTLEMENT AGREEMENT
Is
Parties
1.1 This Compromise Settlement Agreement (the "Agreement") is entered into by
and between The City of Fort Worth, Texas, (herein referred to herein as "Fort Worth"), and
Burnsco Construction, Inc. (herein referred to as "Burnsco) (sometimes Fort Worth and
Burnsco are collectively referred to as the "Parties"), for the mutual consideration and
purposes herein expressed. This Agreement is made by each of the Parties and, if applicable,
their successors, assigns, shareholders, directors, and officers.
H.
Statement Of Dispute
2.1 The term "Disputed Projects" as used in this agreement refers to, and means,
those construction projects constructed in, or for, Fort Worth and for which Burnsco has
provided labor or materials for the construction of improvements, excepting any current or
future projects for which Burnsco has . been awarded work either as a prime contractor or
subcontractor, any projects where any applicable maintenance bond still applies, and those
projects subject to litigation and/or settlement in Cause No. 96-232719-08, City of Fort
Worth v. Crawford Farms Investors, et al.1 ("Crawford Farms Litigation") and any related
settlement of Crawford Farms Phase 4.
2.2 Fort Worth notified Burnsco that it believed there were defects in work
Burnsco performed on several of the Disputed Projects. The Parties have conducted a mutual
1 City of Fort Worth v. Crawford Farms Investors, Ltd., Crawford Partners No. 1, Ltd., Crawford Farms
Partners No. 2, Ltd., Hanover Services Group, Inc., Crawford -GP Partners,.LL-1., Glenn Thurman, Inc., and
Compromise Settlement Agreement
Premature Failed Streets 155 Panels — CFW-Burnscoj
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inspection of all the Disputed Projects and have decided to compromise and settle all matters
and issues regarding the Disputed Projects under the terms and conditions set forth herein in
order to avoid further litigation and to minimize expenses. Nothing in this Agreement is
intended to be an admission of liability or fault on the part of either of the Parties.
III.
Consideration
3.1 All matters relating to the Disputed Projects are compromised and settled
between the Parties to this Agreement in consideration of the mutual releases, promises and
agreements herein expressed.
3.2 Burnsco agrees to perform work and provide materials to remove and replace
a total of One Hundred Fifty Five (155) concrete panels originally constructed as part of
seven (7) different construction projects (or phases) in the Disputed Projects area, as shown
on Exhibit A. The terms and conditions related to this removal and replacement are set out
below, and unless unreasonably delayed by Fort Worth, must be concluded within two (2)
years from Fort Worth's execution of this Agreement. Fort Worth and Burnsco agree that
before any work is performed by Burnsco pursuant to this Agreement, Burnsco will provide a
schedule and Fort Worth will visibly mark the specific panels to be removed and replaced by
Burnsco, in accordance with the information provided in Exhibit A under the Burnsco Work
Order Number One and Burnsco Work Order Number Two.
3.3 Burnsco agrees to provide the labor and materials, and perform the work
pursuant to the specifications developed by Fort Worth (attached hereto as Exhibit "B") for
Burnsco Construction, Inc.
Compromise Settlement Agreement
Premature Failed Streets 155 Panels -- CFW-Burnsco, Inc.
2
replacement of the identified panels; provided however, that for the work and materials
provided by this Agreement: (i) there is no MWBE (or BDE) participation requirements or
reporting; (ii) the street cutting permit will be waived (although Burnsco agrees to adhere to
the standard city traffic control drawings); (in) the pavement repair is to be constructed as
described on Exhibit B; and (iv) Burnsco will give Fort Worth the standard notice of
construction procedures for affected areas.
3.4 Fort Worth shall be entitled to have an inspector on site when the removal and
replacement work is being performed. Fort Worth is further entitled to conduct such testing
that Fort Worth determines is necessary to confirm the quality of the removal and
replacement work performed by Burnsco pursuant to this Agreement. Fort Worth shall be
responsible to paying for any and all tests it conducts, save and except, if any such tests fail
to meet specified construction standards, then Burnsco shall be responsible for retesting
costs.
3.6 Burnsco shall notify Fort Worth, in writing, that the removal and replacement
for a specified project named in Exhibit A, and outlined in Section 3.2, above, has been
completed. Within 30 days from the date of such notice, Fort Worth shall perform any
inspection or testing procedures it deems necessary to ensure the work was completed
pursuant to the plans and specifications, and to provide a detailed list of any deficiencies to
Burnsco. If Burnsco does not receive Fort Worth's wntten notice detailing the deficiencies
within this 30 day period, then Fort Worth shall be deemed to have accepted Burnsco's
performance of the consideration stated herein, in full satisfaction of the claims of Fort
Compromise Settlement Agreement 3
Premature Failed Streets 155 Panels -- CFW-Burnsco, Inc.
Worth on the stated project for which Fort Worth received notice of completion. Burnsco
shall warrant the materials and workmanship of the replaced panels for a period of one year.
3.7 Notwithstanding anything to the contrary herein, neither this Agreement nor
the litigation commenced by Fort Worth related to Crawford Farms will provide a basis for
Burnsco being disqualified as a responsive bidder on future Fort Worth projects, to include
on jobs Contract 2005 WSM-L DOE No. 5882 and Contract 2009 WSM-E DOE No. 6498.
Notwithstanding anything to the contrary herein, Crawford Farms Phases 2 & 4 are
specifically excluded from the terms of this Agreement.
IV.
General and Mutual Release
4.1 In consideration of the good and valuable consideration recited hereinabove,
the sufficiency of which is hereby acknowledged and confessed, each of the Parties hereby
releases, remises, and forever discharges the other Party, their officers, directors,
shareholders, employees, agents, insurers, indemnitors and indemnities, successors and
assigns, from any and all claims, demands, actions, and causes of action of whatever kind or
character known, unknown, accrued or unaccrued, arising or to arise out of and/or connected
with the Disputed Projects, EXCEPT (i) any claim, cause of action, damages and/or expenses
which may arise from the breach of this Agreement; or (ii) any claim, cause of action,
damages, or expenses which may arise from the Crawford Farms Phase 2 and Phase 4
litigation.
V.
General Provisions
Compromise Settlement Agreement
Premature Failed Streets 155 Panels -- CFW-Burnsco, Inc.
5.1 Assignment. The Parties represent and warrant to each other that they have
not, and will not, sell, assign, convey, or otherwise transfer any interest in any claims, rights,
causes of action, obligations, or other liabilities or obligations which are the subject of this
Agreement, except to a direct successor entity of a Party, and that they have the sole right and
exclusive authority to execute this Agreement and release the matters as set forth herein.
5.2 No Third -Party Beneficiary. This Agreement has been executed for the sole
benefit of the Parties hereto and is not intended for the benefit of any third -party, except to
the extent a release is explicitly granted to the third party. No other party shall have any
rights hereunder, nor shall they be entitled to assume that the Parties hereto will insist upon
strict performance of the mutual obhgations arising under this Agreement for the benefit of
such other parties or otherwise. The Parties to this Agreement further agree that they will not
institute, maintain, assist in, or otherwise encourage any suit, action, or other proceeding at
law, in equity, or otherwise against the other party nor aid any third -party in any way in such
proceedings.
5.3 Disclaimer of Liability. The Parties disclaim any liability to each other and
it is expressly understood and agreed that the terms of this Agreement are contractual and not
mere recitals, and that the covenants contained herein and the consideration transferred
herein are to compromise doubtful and disputed claims, avoid litigation, and buy peace, and
that no payments made nor any releases or other consideration given shall be construed as an
admission of liability or wrongdoing by any party to this Agreement, all such liability being
expressly denied.
Compromise Settlement Agreement 5
Premature Failed Streets 155 Panels — CFW-Burnsco, Inc.
5.4 Attornev's Fees. In the event that either Party is required to obtain the
services of an attorney to enforce this Agreement, the prevailing Party, in addition to other
remedies available, shall be entitled to recover reasonable attorney's fees and costs of court.
5.5 Amendments. This Agreement may be amended, revised, waived,
discharged, released, or terminated only by written instrument executed by all Parties hereto.
5.6 No Waiver. No failure to exercise or delay in exercising any right hereunder
on the part of either party shall operate as a waiver thereof, nor shall any single or partial
exercise of any right of a party hereunder preclude any other or further exercise of such right
or the exercise of any other right or rights. The rights of the Parties hereunder shall be in
addition to all other rights provided to the Parties at law and/or in equity.
5.7 Successors and Assigns. All the terms of this Agreement shall apply to and
shall be binding upon and inure to the benefit of the Parties hereto, their respective
successors, assigns, heirs, directors, officers, partners, agents, servants, employees, insurers,
parent companies, subsidianes, and/or legal representatives and/or all persons claiming by,
through or under such parties, as may be permitted herein.
5.8 Applicable Law and Venue. This Agreement has been executed and
delivered in the State of Texas and shall be governed by and construed in accordance with
the laws of the State of Texas and the applicable laws of the United States of America. This
Agreement is performable and enforceable in Tarrant County, Texas.
5.9 Invalid Provisions. If any provision of this Agreement is for any reason held
to be invalid or unenforceable, such provision shall not affect any other provision hereof, but
Compromise Settlement Agreement
Premature Failed Streets 155 Panels — CFW-Burnsco, Inc,
this Agreement shall be construed as if such invalid and/or unenforceable provision had
never been contained herein.
5.10 Leaal Counsel. The Parties hereto acknowledge that (i) they have consulted
with legal counsel regarding the contents of this Agreement; (ii) that they have carefully read
this Agreement and reviewed the same with their legal counsel; (iii) they understand the
terms and legal consequences of this Agreement; and (iv) they acknowledge their acceptance
of the terms of this Agreement by their signatures affixed hereto.
5.11 Representations. The statements and representations contained in this
Agreement are considered contractual in nature and not mere recitals.
5.12 Acknowledgment of Entire Agreement. The Parties do each expressly
represent and warrant that (1) they have entered into this Compromise Settlement Agreement
of their own free will and accord, and in accordance with their own judgment; (2) that they
have not been induced to enter into this Compromise Settlement Agreement by, nor relied
upon, any statement, act, promise, or representation of any kind or character by anyone
hereby released or on the part of their agents or representatives, except for the consideration
expressly recited herein; and (3) that this Agreement represents the entire agreement between
the Parties and that all prior agreements respecting the subject matter hereof have been
incorporated in the terms of this Agreement and are no longer of any force or effect.
5.13 Supplementary Documents. The Parties, individually, and in their
representative capacities, agree to execute any and all supplementary documents and to take
all supplementary steps to give and to effect the basic terms and intent of this Agreement.
Compromise Settlement Agreement 7
Premature Failed Streets 155 Panels — CFW-Burnsco, Inc.
5.14 Effective Date. The effective date of this Agreement shall be the date
appearing opposite the signature of the last party signing this Agreement.
BURNSCO CONSTRUCTION, INC.: CITY OF FORT WORTH TEXAS:
DATED: — Co eft. I Z
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Date q - 2 s - I t_
�L ifriete•••4
Fernando Costa, Assistant City Manager
DATED: /0/8/2
R� r ended By:
Dougla 'j . Wiersig
Director, Transportation/Publi Works
A ; I ro e�; s to Form and Legality:
-tr
Douglas W. Black
Assistant City Attorney
ATTEST:
Mary`f Kay
City Secretary
Compromise Settlement Agreement
Premature Failed Streets 155 Panels — CFW-Burnsco, Inc.
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env SECRETARY
FT. WORTH, TX-
THE STATE OF TEXAS §
COUNTY OF TARRANT §
BEFORE ME, the undersigned Notary Public, on this day personally appeared
Fernando Costa, a representative authorized by the City of Fort Worth, Texas to executed this
Agreement, known to me to be the person whose name is subscribed to the above and
foregoing instrument, and acknowledged to me that s/he has executed the same for the
purposes and consideration therein expressed.
GIVEN UNDER MY HAND AND SEAL OF OFFICE this
Ock-Ohrift 2012.
UND/+M.Hiram IG
MY COMMISSION EXf IUES
F6lvary 2, 2014
STATE OF TEXAS §
COUNTY OF TARRANT §
day of
Nth'ARY PUBLIC, STATE OF TEXAS
BEFORE ME, the undersigned Notary Public, on this day personally appeared John
Burns, President of Burnsco Construction, Inc., known to me to be the person and officer
whose name is subscribed to the above and foregoing instrument, and acknowledged to me
that the same was the act of the said Burnsco Construction, Inc., and that s/he has executed
the same as the act of such corporation for the purposes and consideration therein expressed,
and in the capacity therein stated.
GIVEN UNDER MY HAND AND SEAL OF OFFICE this LsYn day of
S'e‘44ab ex-- 2012.
ras
MARY F PANNELL
My Commission Expires
October 19, 2014
111
NOTARY PIIRLIC, STATE OF TEXAS
Compromise Settlement Agreement
Premature Failed Streets 155 Panels — CFW-Burnsco, Inc.
9
EXHIBITS LIST
Compromise Settlement Agreement 10
Premature Failed Streets 155 Panels — CFW-Burnsco, Inc.
F_BLK T_BLK
12800 12813
12814 12825
12920 12939
12824 12899
12900 12923
12924 12943
11900 11949
12200 12249
F BLK T_BLK
3586 3929
3600 3699
3700 3749
3750 3799
9000 9099
9000 9099
4036 4299
9100 9109
13916 13999
14000 14009
9100 9117
5500 5599
Street
CEDAR HOLLOW DR
CEDAR HOLLOW DR
CEDAR HOLLOW DR
PRICKLYBRANCH DR
PRICKLYBRANCH DR
PRICKLYBRANCH DR
TIMBERLAND BLVD
TIMBERLAND BLVD
•
Street
COUNTRY LN
DIAMOND RANCH RD
DIAMOND RANCH RD
DIAMOND RANCH RD
FOX MEADOW WAY
GARDEN SPRINGS DR
GOLDEN HORN LN
HEDGEROW DR
LOST SPURS RD
LOST SPURS RD
RIDING STABLE LN
SHIVER RD
EXHIBIT "A"
BURNSCO - Premature Failure Replacement Agreement (DRAFT)
5-30-2012
BURNSCO WORK ORDER NUMBER ONE
FromStreet
PANGOLIN DR
12814 CEDAR HOLLOW DR
WILLOW ROCK LN
MARTINGALE VIEW LN
HOUNDS TAIL LN
WILLOW ROCK LN
LYNX LN
HOLLOW VALLEY DR
FromStreet
FOX MEADOW WAY
LOST SPURS RD
FONTANA RD
MOUNTAIN RANCH RD
THOROUGHBRED TRL
THOROUGHBRED TRL
GARDEN SPRINGS DR
COUNTRY LN
MOUNTAIN RANCH RD
DIAMOND RANCH RD
COUNTRY LN
5500 SHIVER RD
ToStreet
12813 CEDAR HOLLOW DR
MARTINGALE VIEW LN
LACEBARK LN
HOUNDS TAIL LN
WILLOW ROCK LN
LACEBARK LN
MOUNTAIN LION DR
LEAFLET DR
Panels
3
1
5
20
24
14
7
9
SqYds
58
20
97
387
464
271
224
172
AddltionPhase
TIMBERLAND BLVD PH 1 B
TIMBERLAND BLVD PH 1A
TIMBERLAND BLVD PH 1A
TIMBERLAND BLVD PH 1A
TIMBERLAND BLVD PH 1A
TIMBERLAND BLVD PH 1A
WOODLAND SPRINGS WEST TIMERLAND PH 1 "
1 DOE_#
4920
4559
4559
4559
1 4559
4559
3574
WOODLAND SPRINGS WEST TIMERLAND PH 1 " 13574
WEST TIMERLAND PH 1
83 1 1693
BURNSCO INSTALLED STORM DRAIN FOR WOODLAND SPRINGS WEST TIMERLAND PH 1
r- .,..,. }..r i. S :4•r. ..1, Y=:r:..P... r.. ....4 i,.er..v._�3.,-_,.a..—,.,r ,.
B'IRNSCO WORK ORDER NUMBER TWO
ToStreet
HEDGEROW DR
FONTANA RD
MOUNTAIN RANCH RD
LAN RIVER RANCH RD
COUNTRY LN
COUNTRY LN
TROY DR
9109 HEDGEROW DR
DIAMOND RANCH RD
LOST SPURS RD
FOXHOUND LN
SCOTTS VALLEY ST
TOTAL - WK ORDER 1 & 21
Panels SqYds
4 47
6 116
6 116
10 145
4 47
18 171
2 32
5 81
4 74
4 81
2 18
7 113
72 1041
155 2734
AdditionPhase
POYNTER CROSSING PH 1
LOST CREEK RANCH NORTH PH 3
LOST CREEK RANCH NORTH PH 3
LOST CREEK RANCH NORTH PH 3
POYNTER CROSSING PH 1
POYNTER CROSSING PH 1
POYNTER CROSSING PH 1
POYNTER CROSSING PH 1
LOST CREEK RANCH NORTH PH 3
LOST CREEK RANCH NORTH PH 3
POYNTER CROSSING PH 1
VINEYARDS AT HERITAGE PH 2
PMF Burnsco Agreement_EXHIBIT A 5-30-2012 DRAFT.xIs 1 5/30/2012
DOE #
3512
3919
3919
3919
3512
3512
3512
3512
3919
3919
3512
3202
MIM
Timberland Blvd
NOT TO SCALA
Exhibit "A"_Burnsco Work Order # 1
CELLER?HASL',ET_
Prickiybranch Dr
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sty
0 0 1..„,r.Se'' 4� j� r ' '. W t ' 11MBERLAND
,:FURLONG :;'.4 m� ;•.,.,;
..mDAISY' LEAF; 6001:
•
_a= %i •r•
'7 •
LACE $, A
'Y,-. 'r..,v..
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HUNDS VTA' .,.,•
ELLOW-BIRCH REOtUM,
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Copyrlt/t12012 City of rod Worth. Unauthorized reporduolon Ise violation of apple; able lows.
This product is for informational purposes end may not have been prepared for re be suitable for legal, engineering, or surveying purposes.
It does not represent an on-th-ground survey and represents only the approximate retalva location of property boundaries.
Meetly of Fort Worth assumes no responsibility for the acwricy of said data.
.
GRAY F.P
"Ir4I. ':..:: GOLDENI
Exhibit "A" Burnsco Work Order # 2
w
Golden Horn Ln
Fox Meadow Way
Copyd Olt 2012 City of Fad Worth. Uneulhodzed repordtslon Is a vloladon of applicable laws.
This pmduct is tor Iltornatlonal purposes and may net have been pmpered for or be suitable for legat enginening, or surveying purposes.
1 does not represent an on•1Mground survey and represents any the appromnab Salve location of pmpedy boundaries.
The Cdy effort Worth assumes no responslbi ty for the aceuney at said data.
HOT ID :CALA
Exhibit B
Technical Specs for Replacement of Concrete Street Panels
The scope of work shall include the removal of existing concrete pavement and the
reconstruction of a minimum six (6) inches reinforced concrete pavement, #3 steel on 18
inch centers using 3H Chairs to elevate. over eight (8) inches of' well graded flex -base
(TxDOT, Type A, Grade 2) over geo-grid (TensarTriAx TX140-475). This repair
procedure shall be used where utility trenches (including service Imes) exist beneath the
area to be replaced. The geo-grid and flex -base shall be installed within the full limit of
the replacement area. The surface below the geo-grid and flex -base must be compacted to
95%. If space permits, compacted area shall be_proof rolled. Existing voids and
unsuitable material below the pavement shall be corrected as directed by the City.
M&C Review
Page 1 of 2
DATE:
Official site of the City of Fort Worth, Texas
FORT WORT I
COUNCIL ACTION: Approved on 9/25/2012
9/25/2012 REFERENCE NO.: **G-17682
CODE: G TYPE:
SUBJECT:
LOG NAME:
PUBLIC
HEARING:
Approve Settlement of Claims in City of Fort Worth v. Crawford Farms Investors, Ltd., et
al., and Settlement of Other Claims with Burnsco Construction, Inc. Regarding
Prematurely Failed Streets (COUNCIL DISTRICTS 2 and 6)
CONSENT
12SETTLE
BURNSCO
NO
RECOMMENDATION:
It is recommended that the City Council approve settlement of claims in City of Fort Worth v.
Crawford Farms Investors, Ltd., et al. and settlement of other claims with Burnsco Construction, Inc.
regarding prematurely failed streets in north Fort Worth.
DISCUSSION:
In 2008, the City Council authorized a lawsuit against Burnsco Construction, Inc. (Burnsco) over
various street failures allegedly caused, at least in part, by Burnsco. This case was styled as cause
number 96-232719-08, City of Fort Worth v. Crawford Farms Investors, Ltd., Glenn Thurman, Inc.,
L.H. Lacy Company Ltd., and Burnsco Construction, Inc. (Crawford Farms Litigation). Earlier this
year, the parties agreed to mediate the case. The result of the mediation was that Burnsco and
Crawford Farms Investors, Ltd. agreed to pay the City $300 000.00, which payment was received in
June 2012. Staff was previously authorized to negotiate a settlement in the Crawford Farms Litigation
by the City Council.
In late 2011, Burnsco, bidding on city infrastructure projects, was the apparent low bidder for two
Water Department projects. Staff recommended denial of the award of the contracts citing the
ongoing Crawford Farms Litigation. During subsequent discussions with Burnsco regarding this
recommendation, Burnsco s representative offered to repair various other streets constructed by
Burnsco which had also allegedly failed prematurely and were not part of the Crawford Farms
Litigation (Other Failed Streets). Staff and Burnsco representatives agreed that Burnsco will repair 55
street panels equal to approximately 0.36 lane miles on 12 streets at Burnsco's expense, estimated at
$173 000.00. Acting in good faith, staff subsequently recommended award of the two Water
Department contracts to Burnsco, both of which projects are underway. It is anticipated that Burnsco
will begin making repairs to the Other Failed Streets on or before October 25, 2012.
Approval of these two settlement agreements will settle all claims the City has against Burnsco for
prematurely failed streets constructed by Burnsco between June 2002 and October 2008 and will
hasten repairs to the identified streets.
This project is located in COUNCIL DISTRICTS 2 and 6.
FISCAL INFORMATION/CERTIFICATION:
The Finance Director certifies that approval of the above recommendations will have no material
impact on City funds.
http://apps.cfwnet.org/council_packet/mc_review.asp?ID=17428&councildate=9/25/2012 10/8/2012
M&C Review Page 2 of 2
TO Fund/Account/Centers FROM Fund/Account/Centers
Submitted for Citv Manaaer's Office bv: Fernando Costa (6122)
Oriainatina Department Head: Sarah Fullenwider (8006)
Additional Information Contact: Doug Black (7615)
ATTACHMENTS
http://apps.cfwnet.org/council_packet/mc_review.asp7ID 17428&councildate=9/25/2012 10/8/2012