HomeMy WebLinkAboutexhibit 2-settlement and release agreementCOMPROMISE, SETTLEMENT AND RELEASE AGREEMENT
This Compromise, Settlement and Release Agreement ("Settlement Agreement"), dated
this day of , 2004 is entered into by and between Raceworks, LLC ("Raceworks"),
a Delaware limited liability company, authorized to conduct business in the State of Florida, and
the City of Miami ("City"), a municipal corporation of the State of Florida
WITNESSETH
WHEREAS, the City, Trust and Raceworks executed a Revocable License Agreement
("Agreement") on May 22, 2002, as amended, for Raceworks to conduct motor vehicle racing
events in Downtown Miami; and
WHEREAS, Raceworks, LLC was granted a permit, in accordance with Section 549.08,
Florida Statutes ("Motor Sports Act"), to conduct a racing event in Downtown Miami on
September 26-28, 2003 called Grand Prix Americas ("2003 Race Event"); and
WHEREAS, pursuant to the Agreement, Raceworks is required to remit to the City
payment for the Use Fee, Ticket Fee, and any other obligations incurred as a result of the event;
and
WHEREAS, the City has found the Raceworks to be in default of the Agreement due to
its failure to pay to the City its use fee, its ticket fee and to satisfy its outstanding financial
obligations with regard to the 2003 Race Event (the "Incident"); and
WHEREAS, the City and the Raceworks wish to settle all outstanding financial
obligations associated with the 2003 Race Event; and
WHEREAS, as a result of the 2003 Race Event, Raceworks owed the City $104,401.05
as payment for its use fee, ticket fees and other financial obligations; and
WHEREAS, Raceworks has agreed to forfeit its claim to payment by the City in the
amount of $19,473.00, which was retained by the City as payment of police and fire surcharges,
thereby reducing the amount owed to the City to $84,928.05.
WHEREAS, the Raceworks has proposed the settle the outstanding debt in the amount of
$33,971.22 in exchange for the City executing this Settlement Agreement, which would release
the Raceworks for its financial obligations as a result of the 2003 Race Event.
NOW, THEREFORE, in consideration of the mutual covenants and conditions contained
herein, the receipt and sufficiency of which is hereby acknowledged, the parties agree as follows:
1. Recitals: The recitals are true and correct and are herby incorporated into and
made a part of this Settlement Agreement.
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BPMT and Raceworks, LLC
2. Racework' OOligittions: On or before June 1, 2004, Raceworks shall pay to the
City $33,971.22, payable in check from Raceworks' account, for amounts due as a result of the
2003 Race Events.
3. Conditions of the Release:
A. This Settlement Agreement shall only be effective upon 1) receipt by City
of the check referenced above and the funds being cleared in the name of
the City, 2) the check clearing Raceworks' account, and 3) the City is not
ordered by a court of competent jurisdiction to return the payment as a
result of a bankruptcy proceeding or any other legal proceeding, after full
exhaustion of appellate review. In the event that these conditions are not
met, then this Settlement Agreement shall become null and void and
neither party shall have any further obligations hereunder.
B. Raceworks agrees to release and forfeit any and all claims . to the
$ 1.9,473.00 in police and fire surcharges assessed by the City during the
2003 Grand Prix Americas in violation of Section 11 of the Revocable
License Agreement. Raceworks acknowledges that the $ 19,473.00
previously remitted to the City shall be used to reduce its total outstanding
debt of $ 104,401.05 from the 2003 Race Events to a current balance of
$84,928.05.
C. Raceworks understands that the City considers Raceworks in default of the
agreements that Raceworks has entered into with City. In consideration of
City executing this Settlement Agreement and in lieu of the City initiating
proceedings pursuant to the City of Miami's Debarment and Suspension
Ordinance, Section 18-107, City of Miami Code (2004)C'Debarment
Ordinance") and the Debarment Regulations which are contained in City
of Miami Resolution No. 02-1325, which has been previous provided by
City and reviewed by Raceworks prior to executing this Settlement
Agreement, Raceworks agrees to be debarred for a period of five (5) years
and Raceworks hereby knowingly, voluntarily and intentionally waive its
procedural and substantive rights pursuant the Debarment Ordinance and
Regulations, including, but not limited to, its right to a written decision
from the City Manager stating the reasons for the debarment or suspension
and right to seek judicial relief therefrom. This provision shall survive the
termination of this Release.
D. Raceworks understands in order to reach this settlement the City is
accepting forty percent (40%) percent of the amount due to it. In the event
COMPROMISE, SETTLEMENT AND RELEASE AGREEMENT
BPMT and Raceworks, LLC
Page 3 of 4
that Raceworks compensates any other creditor ("Another Creditor") a
higher percentage of the amount due to them, respectively, by Raceworks,
then Raceworks shall remit to City a proportionate amount of additional
funds commensurate with the amount of compensation received by
Another Creditor. This provision shall survive the termination of this
Settlement Agreement.
4. Release: In consideration of and in accordance with the terms and conditions
contained above, Raceworks and City hereby agree to mutual release the other, their
administrators, successors, assigns, subsidiaries, parents, related entities, heirs, executors and
administrators and all directors, officers, employees, members, and agents from all actions,
causes of actions, suits, debts, dues, sums of money, accounts, reckonings, bills, covenants,
contracts, controversies, agreements, promises, variances, trespasses, damages, judgments,
executions, claims, and demands whatsoever in law or equity, which any party may have against
the other, its successors, assigns, subsidiaries, related entities, and other entities or individuals set
forth above, ever had, now have, or hereinafter can, shall, or may have for, upon or by reason of
any matter, cause, or thing whatsoever from the beginning of the World to the date of this
Settlement Agreement with regard to the Incident.
4. Authority:
A. The Commission of the City of Miami, by Resolution No. -
adopted on , 2004, the City Manager to
execute this Settlement Agreement, under the terms and conditions set
forth herein.
B. Raceworks represents that it has the authority to enter into this Settlement
Agreement and bind its to such terms. A corporate resolution indicating
its authority to enter into this Release is attached hereto.
5. Miscellaneous Provisions:
A. This Settlement Agreement shall be self -operative and automatically be in
full force and effect upon collection of the funds due here under.
B. No change or alternation of this Settlement Agreement shall be valid or
binding unless such change or alteration be in writing and executed by
each of the parties hereto.
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BPMT and Raceworks, LLC
C. This Settlement Agreement represents the entire understanding of the
parties concerning their prior actions or agreements, whether oral or
written, and shall be merged into and made part of this Settlement
Agreement
D. This Settlement Agreement shall be construed and enforced according to
the laws of the State of Florida. Venue for any legal proceedings shall be
Miami Dade County.
IN WITNESS WHEREOF, the parties have signed this Compromise, Settlement and
Release Agreement
Attest: RACEWoRKS,
Print 4a e: /ilri ells: i z 4t if' Chuck M. Martinez
Print -Title.
Attest:
Priscilla A. Thomson
City Clerk
Approved as to risk requirements:
Dania Carrillo
Risk Management Administrator
Preside',
PARTY
City of Miami, a municipal corporation
of the State of Florida
Joe Arriola
City Manager
Approved as to form and correctness:
Alejandro Vilarello
City Attorney