Loading...
HomeMy WebLinkAboutResolution 5746-06-2023A Resolution NO.5746-06-2023 AUTHORIZING THE CITY ATTORNEY TO FILE A PETITION FOR TEMPORARY INJUNCTION AGAINST MMC MANAGEMENT SERVICES, INC. WHEREAS, the City of Fort Worth ("City") is in the design stage of constructing the Mary's Creek Force Main project ("the Project'). The Project is a high -priority Water Department project that will transport wastewater to the future Mary's Creek Water Reclamation Facility in order to treat wastewater produced in the rapidly developing western part of the City and source high -quality reclaimed water for future businesses and industries in the area; and WHEREAS, to complete the Project, the City must access property owned by MMC Management Services, Inc. in order to conduct surveying and other due diligence work, said property being located at 9816 Lorie Valley Trail and being described as Tarrant Appraisal District Account No. 42628413, Montrachet Addition, Block 1, Lot 35, Tarrant County, Texas; and WHEREAS, the City has repeatedly sought to coordinate its survey and due diligence activities with MMC Management Services, Inc. by entering into a voluntary access agreement that would allow the City to conduct the due diligence activities it is entitled to conduct under the law; and WHEREAS, efforts to obtain permission to enter the property in order to perform due diligence work have been unsuccessful thus preventing the City from completing the due diligence activities that need to be conducted in order for the Project to move forward; and WHEREAS, the City's failure to legally conduct survey and other due diligence work on the property places the ultimate design and construction of the Project in jeopardy; and WHEREAS, because the City is vested with the power of eminent domain, the City is legally entitled to enter the property and conduct the due diligence activities necessary to successfully complete the Project; and WHEREAS, pursuant to Section 65.011(1) of the Texas Civil Practice and Remedies Code, injunctive relief is appropriate when the applicant is entitled to the relief sought and such relief requires the restraining of some act prejudicial to the applicant. As a matter of law, the City is entitled to enter upon the property to conduct its due diligence and the property owner(s) should be restrained from interfering with the City's exercise of this legal right. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF FORT WORTH, TEXAS THAT: The City Council authorizes the City Attorney to file a Petition for Temporary Injunction against MMC Management Services, Inc., the owner of 9816 Lorie Valley Trail, in order to preserve the status quo and to protect the City's statutory right to access the property to conduct the survey and due diligence activities necessary to proceed with the Project. Adopted this 13th day of June 2023. pow Fon? 11 ATTEST: �� F°°°000°°00 0 0 °° ° A 0 .0 $9A 0 By. _ P� 0 o o C 0 0 4 Jannette S. Goodall, City Secretary �Q °°°°-_ _„000 4� EMT NAA -�rrrall • lillip 24 7 jbdmmw— s F, �T- IDD r4 4 4 4 ✓� y r l T .r ■ - JFts. Y DRAFT MARY'S CREEK FORCE MAIN ALIGNMENT FOR SURVEY/ EASEMENT N Proposed Survey/Easement Parcel Boundary - - - - NHD Flowline w Existing Sewer Line S — —i Exisitng Sewer Line 20ft Easement City of Fort Worth, Texas Mayor and Council Communication DATE: 06/13/23 M&C FILE NUMBER: M&C 23-0478 LOG NAME: 21INJUNCTION P29 MMC MGT. SERVICES CHILDRESS SUBJECT (Near CD 3) Adopt Resolution Authorizing the City's Petition for a Temporary Injunction Against MMC Management Services, Inc., the Owner of Property Located at 9816 Lorie Valley Trail in the Montrachet Addition, Block 1, Lot 35, Tarrant County, Texas, Seeking a Temporary Right of Entry to Conduct Due Diligence in Anticipation of the Mary's Creek Force Main Project RECOMMENDATION: It is recommended that the City Council authorize the City Attorney to file a petition for a temporary injunction against MMC Management Services, Inc., the owner of property located at 9816 Lorie Valley Trail in the Montrachet Addition, Block 1, Lot 35, Tarrant County, Texas to gain access to the property in order to conduct due diligence necessary for the Mary's Creek Force Main project. DISCUSSION: Approval of this Mayor & Council Communication (M&C) would authorize the City Attorney to file a petition for a temporary injunction against MMC Management Services, Inc., the owner of property located at 9816 Lorie Valley Trail in the Montrachet Addition, Block 1, Lot 35, Tarrant County, Texas, to gain access to the property in order to conduct due diligence necessary for the Mary's Creek Force Main project (Project). The Project is a high -priority Water Department project that will transport wastewater to the future Mary's Creek Water Reclamation Facility in order to treat wastewater produced in the rapidly developing western part of the City and source high -quality reclaimed water for future businesses and industries in the area. The property is in the central portion of the Project and currently owned by MMC Management Services, Inc., a Texas corporation managed by Mark M. Childress. Efforts to obtain permission to enter the property to perform due diligence work have been unsuccessful. Therefore, staff seeks Council authority to file suit to obtain a temporary injunction to allow employees of the City of Fort Worth, registered contractors, consultants, and their sub -consultants to enter the property to perform due diligence work. As part of the due diligence for the Project, a Temporary Right of Entry is needed to perform the following: 1. Geo-technical analysis to include shovel testing and borings (backfilled upon drilling); 2. On -the -ground survey and appraisal; 3. Environmental jurisdiction determination to identify open waters or wetlands; 4. Environmental archaeological site review to identify cultural resources from history of operations in the area to include shovel testing along the alignment and backhoe trenching at key areas and creek crossings (backfilled upon completion); 5. Subsurface utility exploration to include Quality Level A Test Holes (backfilled upon completion); 6. In -situ soil resistivity testing to identify soil resistivity along the proposed alignment; and 7. General site observation. Accordingly, it is recommended that the City Council adopt the attached resolution authorizing the filing of the Petition for Temporary Injunction in Tarrant County, Texas. This property is near COUNCIL DISTRICT 3. A Form 1295 is not required because: This M&C does not request approval of a contract with a business entity. FISCAL INFORMATION / CERTIFICATION: The Director of Finance certifies that approval of this recommendation will have no material effect on City funds. Submitted for City Manager's Office by. Dana Burghdoff 8018 Originating Business Unit Head: Steve Cooke 5134 Ricky Salazar 8379 Additional Information Contact: Niels Brown 5166 Janice Holmes 6349