CCR1998040COMMON COUNCIL - CITY OF MUSKEG0
RESOLUTION #40-98
RESOLUTION APPROVING SETTLEMENT AGREEMENT
CITY OF MUSKEG0 - TOWN OF NORWAY SANITARY DISTRICT #l
WHEREAS, the City of Muskego and Sanitary District #I of the Town of Norway are
involved in litigation concerning the interpretation of a certain contract between the City
and the Sanitary District dated April 6, 1978, concerning the District supplying certain
sewer services to certain areas of the City of Muskego, and
WHEREAS, said parties are interested in resolving said dispute.
NOW, THEREFORE, BE IT RESOLVED that the Common Council of the City of
Muskego hereby approves of the attached settlement agreement and authorizes the
Mayor and City Clerk to execute the same and to take any other reasonable necessary
steps to conclude said dispute.
DATED THIS 24TH DAY OF MARCH, 1998.
SPONSORED BY:
David L. De Angelis, Mayor
This is to certify that this is a true and accurate copy of Resolution #40-98 which was
adopted by the Common Council of the City of Muskego.
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WHEREAS, the Sanitary Department No. 1 of the Town of Norway,
hereinafter referred to as "City", entered into an Agreement on
hereinafter referred to as the "District", and the City of Muskego,
April 6, 1978 by the terms of which the District agreed to furnish
a limited amount of sanitary sewer service to a limited area within
District syetem subject to certain terms and conditions: and
the City and further agreed to permit additional connections to the
WEEREAS, the City presently has 365 residential unit
equivalents which are served by the District's system; and
WHEREAS, the City brought suit against the District in
Waukesha County Circuit Court on or about June 11, 1997, as Case
No. 97CV1277, challenging the District's interpretation of the
gallonage limitation contained in the aforementioned agreement} and
WHEREAS, the City and the District desire to avoid the time
and expense of protracted litigation and to avoid further
litigation, which is now pending or which may be brought in the
future, and further desire to settle and compromise the dispute
regarding the gallonage limitation contained in the aforementioned
agreement, e
NOW, therefore, for good and valuable consideration, the
parties agree as follows:
agreed between the City and the District that in addition to the
present 365 residential unit equivalents there are an additional 70
reeidential unit equivalents which are committed to being served by
the District syatem, for a total of 435, consisting of the
following:
1. -ConnectianB, c It is therefore recognized and
a. It is recognized and agreed that the Muskego Middle
School presently under construction shall be connected to the
unit equivalents of service by the District.
District syatem and when completed shall congtitute 30 residential
b. It is further recognized and agreed that an
available from the District to service those properties within the
additional 40 residential unit equivalents of service shall be
City which presently abut on sewer mains serviced by the District
but which have not yet been connected to sewer mains.
City shall limit the total number of residential unit equivalenta
which is inclusive of the 435 residential equivalent to units
and the DiStrict'6 obligation to service shall not exceed 540,
2. MConnectiana. It is further agreed that the
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described in paragraph 1 above. The City further agrees that it
connections to the District system which shall exceed 20
shall not request nor shall it be granted permission to make
after January 1, 1998, exclusive of the 70 residential equivalent
residential equivalent units in any calendar year commencing on or
units described in paragraphs la and lb above, until such time as
the parties negotiate and execute a new Agreement or until the
paragraphs la and lb, totale 540, whichever occurs first.
total number of residential unit equivalents, including the 70 in
3. pismiaaa1 of Lamuit. It is further understood and
agreed that upon execution of this Settlement Agreement, the
parties authorize their respective attorneys to cause the dismissal
on ia merits of the afore-described lawsuit pending in Waukesha
County Circuit Court without coats to any party.
Settlement Agreement, neither the City nor the Dietrict is relying
4. No Reliance on Repreaentations. In executing this
upon any statement or representation made by or on behalf of the
other party above named.
5. No Admiasion of Liabilitv. Nothing contained in this
party or the other is correct in the interpretation of the April 6,
Settlement Agreement shall be construed as an admission that one
Settlement Agreement is a compromise settlement.
1978 agreement above mentioned, it being understood that this
0 6. Joint Partlcibation in Preparation of Aareement. The
parties hereto participated jointly in the preparation and
negotiation of thie Agreement, and each party has had the
opportunity to obtain the advice of legal counsel and to review,
comment upon and redraft thie Agreement. Accordingly, it is agreed
that no rule of construction shall apply against any party in favor
of the other party. This Agreement shall be construed as if the
parties jointly prepared this Agreement, and any uncertainty or
ambiguity ahall not be interpreted against any one party and in
favor of the other.
7. Severability. If any of the provieions of this Agreement
are rendered invalid by a Court or government agency of competent
jurisdiction, it is agreed that such holding shall not in any way
Agreement which shall remain govern the validity and interpretation
or manner affect the enforceability of the other provisions of this
of this Agreement.
8. Scope of Aareement. The parties hereby affirm and
acknowledge that they read the foregoing Agreement, and that they
with a counsel or attorney of their choice, and that they fully
have had sufficient time and opportunity to review or discuss it
understand and appreciate the meaning of each of its terms, and
that it is a full, voluntary and final compromise, and settlement
with respect to the City's claim, all of which more particularly
appears in the pleadings and papers on file in Waukesha County
Circuit Court Case No. 97CV1277. The parties to this Agreement
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subsequent proceeding in which any of the parties allege breach of
represent that thin Agreement may be used as evidence in a
this Agreement or seek to enforce its terms, provisione, or
obligations. No promise or agreement made eubsequent to the
execution of this Agreement by these partiee ahall be binding
unless reduced to writing and signed by these parties or their
authorized representatives.
CITY OF MUSKEGO
Attest:
Date By 8 Norman Schultz, President
Attest:
Ronald Drenzek, Secretary