HomeMy WebLinkAbout00327C - AGUA CALIENTE CAHUILLA INDIANS TRIBAL GAMING MOU Agua Caliente Band of Cahuilla
Indians - MOU - Establish
Tribal Gaming Enterprise
AGREEMENT #327C A#3361
R919, 3-2-94
MEMORANDUM OF UNDERSTANDING
BETWEEN
AGUA CALIENTE BAND OF CAHUILLA INDIANS
AND
CITY AND REDEVELOPMENT AGENCY OF PALM SPRINGS
CONCERNING THE ESTABLISHMENT OF
A TRIBAL GAMING ENTERPRISE
R E C I T A L S O F F A C T
A. Since at least 1977, the Aqua Caliente Band of Cahuilla
Indians, a federally-recognized sovereign Indian tribe (the
"Tribe" ) , and the City of Palm Springs (the "City") , a municipal
corporation and a political sub-division of the State of California
(the "State" ) , have made cooperative efforts to achieve the highest
and best use of Indian trust lands located within the City
consistent with principles of sound land use planning, and
generally to develop avenues of cooperation between the Tribal
Government and the City Government for the mutual benefit of
members of the Tribe and residents of the City.
B. The Redevelopment Agency (the "Agency" ) has been
established pursuant to the Community Redevelopment Law (Health and
Safety Code § 33000, et sea. ) to alleviate conditions of blight,
including physical obsolescence, deterioration and dilapidation;
economic dislocation and disuse; and a prevalence of depreciated
values, impaired investments and social and economic maladjustment
within defined project areas . The Agency has adopted the Tahquitz-
Andreas Project Area encompassing significant portions of the Palm
Springs downtown area. Pursuant to the Tahquitz-Andreas
Redevelopment Plan (the "Plan" ) , the Agency has the power to
acquire sites for redevelopment including by condemnation and the
power to dispose of such sites to redevelopers who will develop
them in accord with the Plan. The City and Agency are collectively
referred to herein as the "Public Entities . "
C . Under the Indian Gaming Regulatory Act of 1988, the Tribe
may engage in Class II gaming without any particular relationship
with the City or the State, and may engage in Class III gaming
pursuant to a compact with the State . The Tribe is now pursuing
such a compact by means of litigation and negotiation. The current
draft of such a compact provides , at Paragraph 25 .4, that "in lieu
of complying with sub-paragraphs 25 . 1 - 25 .3 and sub-paragraphs
26 . 1 - 26 . 2 [regarding environmental impact, construction
standards, fire safety, and emergency medical services] , the Tribe
may negotiate one or more separate agreements with affected local
jurisdictions" on these subjects .
NS2\276\014084-000M2071566 9 02/18/94
This Memorandum of Understanding ( "MOU" ) is intended to
perform this function and to set forth avenues of cooperation
between the Tribe and the Public Entities with the goal of a Tribal
gaming enterprise which will be a major benefit to both the Tribe
and the community.
D . The immediate purpose of this MOU is to set forth the
terms of the Agreement of the Tribe and the Public Entities
regarding assembly of a set of parcels of land to be used for and
in conjunction with the Tribe' s planned gaming enterprise. The
longer term purpose of this MOU is to describe how the Tribe plans
to mitigate the environmental and other impacts to the City and
City services from the construction and operation of the gaming
enterprise (the "Casino" ) . The City has already had each of its
department heads perform an informal evaluation of what each
expects such impact to be, the Tribe has considered their reports .
The Tribe and the City have agreed that the mitigation measures
described in this MOU adequately address and mitigate those
impacts .
E . The Tribe has chosen Caesars World, Inc . ( "Caesars" )
through its subsidiary as its manager and operator of the Casino
facility. The Public Entities agree that Caesars' experience and
resources make them uniquely qualified to make the Casino
successful . The Tribe has chosen a site (the "Site" ) for its
Casino that is close to the downtown area of the City, within
walking distance of many major hotels, restaurants, and retail
establishments . The Tribe and the Public Entities expect that
construction and operation of such a first-class Casino at this
location by Caesars will be a major benefit to the local economy in
terms of increased retail, tourist, and real estate activity,
employment during construction and operation, tax base (property,
employment, transit occupancy, sales, etc . ) , and connecting Palm
Canyon Drive with a pedestrian mall to the Casino and Convention
Center. The acquisition of the Site and development of the Casino
thereon is referred to herein as the "Project . "
F . In undertaking the Project, the Public Entities are
required to conduct a variety of public hearings, including to
enter into an agreement to dispose of property (Health and Safety
Code § 33433) , and to acquire property by eminent domain (Code of
Civil Procedures § 1230 . 010 et seo. ) , consideration of variance
applications and to vacate streets (Streets and Highway Code
§§ 8300 et secr. ) . The Public Entities cannot prejudge these
matters, and it is therefore understood that this MOU is at this
time conceptual and a statement of intent only. This MOU is at
this time in the nature of an agreement to agree and is
unenforceable in a court of law. It nevertheless represents a
strong commitment on the part of the parties to cooperate to
realize the Project, and charts a course of action which can
accomplish this goal .
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T E R M S O F U N D E R S T A N D I N G
1. Participation Formula. Because the Tribe and the City
agree that it is not possible to quantify the exact nature and
magnitude of the above environmental impacts, especially regarding
increased demand for City services, and because the Tribe and the
City agree that there will be no income until the Tribe has met its
fixed and other operating expenses" the Tribe and the City agree
that, in full mitigation of such impacts, the Tribe will pay the
following sums to the City, according to a schedule to be agreed by
the Tribe and the City, based on the following percentages of
"Casino Win" :
PARTICIPATION FORMULA
Annual Casino Win Percentage Paid to City
Up to $18, 555, 000 Oo
$18 , 555 , 001 to $28, 555, 000 306
over $28, 555, 000 206
"Casino Win" is defined as excess of gross revenue from all
forms of gaming conducted on the Site over prize payouts for gaming
wins by customers less bad debt from customer gaming and promotional
discounts and allowances . For purposes of this definition,
"promotional discounts and allowances" means all incentives in cash
or in kind provided to casino customers to promote and encourage
gaming at the Site.
Payments shall be made annually. Each payment to the City
accompanied by the certification of the auditing firm employed by
the Tribe as to the accuracy and validity in accordance with the
Participation Formula. The Participation Formula will not be
reduced due to the Tribe' s negotiation of its compact with the
State . The Participation Funds paid to the City by the Tribe
hereunder are intended to mitigate the perceived impact on municipal
services , particularly public safety services, from the operation of
the Casino on the site. The City will annually provide a report to
the Tribe identifying the specific purposes for which the
Participation Funds received by City have been spent, but the Tribe
shall have no right to in any manner direct such expenditures .
2 . The Project. The Project is the acquisition of a site
containing the following components :
a. A gaming area of approximately 7 acres consisting of
the Agency, Walter, Segundo and Browne Parcels
identified in Section 3 below, and herein referred
to as the "Gaming Area" ;
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b . An entry, access, parking and accessory area of
approximately 3 acres consisting of the Post Office
and Hirsch Parcels identified in Section 3 below and
herein referred to as the "Accessory Area. "
The Tribe proposes to construct an approximately 80, 000 square
foot gaming casino including restaurant, associated retail shops,
parking and administrative areas . The Project is estimated to cost
$25 million for land and improvements . The Tribe agrees to commence
construction of the Casino within four (4) years of the date hereof
(the "Commencement Date" ) . The Tribe and the City will discuss,
pursuant to their 1977 Land Use Agreement, obtaining all City
permits necessary for the construction of the Project . The Tribe
will pay all customary building and development charges, fees and
assessments of City reasonably incurred for services actually
rendered, and to discuss with City any other development fees and
charges which might otherwise be assessable against the Project . In
addition, the Tribe will deposit funds with City sufficient to pay
for all of the City' s direct costs actually paid to third parties
for actual services rendered, such as to the environmental
consultant for preparation of the Environmental Assessment, but not
for the City' s in-house staff costs, such as planning, legal,
administrative, etc . , all according to a budget to be approved by
the Tribe in advance of the City' s incurring such direct third-party
costs . If the Tribe provides such funds the City will process all
such matters in the most expeditious manner possible and will
promptly meet directly with the Tribe, at either the City Council or
staff level, as the Tribe may request, to hear any claim by the
Tribe that any aspect of the process is being unreasonably or
unnecessarily delayed. To the extent that a compact for any form of
Class III gaming other than off-track wagering on horse races is in
effect between the Tribe and the State of California, the Tribe may,
at its option, elect to use any procedures provided for in that
compact in lieu of the procedures described above in this paragraph,
but will still informally consult with the City as it does so.
In planning and developing the Site, the Tribe will make a good
faith effort to include retail and other uses of the Site who under
the laws of the State of California will produce tax revenues
beneficial to the City.
The Tribe and the City will have their staffs conduct a speedy
joint planning effort to take those land use related steps necessary
for the construction and operation of the Casino at its chosen
location with primary vehicular access from Indian Avenue and a
pedestrian mall along roughly the route of Andreas Avenue from Palm
Canyon Drive to the Convention Center. Regarding issues such as
traffic, the City and Tribal staffs will invite the participation of
representatives of the Walter Family Partnership to achieve traffic
flow and vehicular access to the Hilton Hotel at least comparable to
that presently existing. Doing so will entail a traffic study,
creation of a new casino zone, zone changes for additional parcels
outside the new casino zone, potential variance applications, etc .
At the locations identified by this joint planning study, the City
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agrees to hold a hearing to vacate its or the public' s interest in
portions of Calle Encilia and Andreas Avenue, and, if the vacation
is approved, to convey all its right, title, and interest in and to
those vacated lands to the United States in trust for the Tribe .
The City will be responsible for conducting a legally adequate
environmental review process meeting the requirement of NEPA and
CEQA. The environmental consultant shall be under contract to the
City. Tribe shall be closely involved in the environmental review
process and shall have the right to review and approve, in advance,
the identity of the consultant, all drafts, and all progress
payments . The Tribe and City shall meet further to develop an
agreement outlining more specifically the process for coordination
of environmental review. The goals of this environmental review
process will be not only to satisfy the requirements of NEPA and
CEQA, but also to produce environmental review documents and
decisions based on them which will not be vulnerable to legal
challenge nor subject to unnecessary or unreasonable delay in
formulation or approval . Notwithstanding the foregoing, the City
retains the sole right to retain the consultant and pay the
consultant, but the City' s entitlement to payment from the Tribe
shall be dependent upon the Tribe' s approving the matters specified
above, but not contingent on the ultimate outcome of the Project or
the hiring of any specific consultant .
In the event of any litigation challenging any project
approvals, including of the Environmental Assessment, the Tribe
shall be responsible for the cost to defend such approvals . The
choice of legal counsel shall be subject to the Tribe' s approval .
The Tribe shall deposit sufficient funds to conduct the defense and
shall supplement the funds as needed.
3 . The Site. The Site is an approximately 10-12 acre area as
shown on the "Site Map" attached as Exhibit "A. " The Site consists
of the following parcels :
Parcel Ownership Designation
(a) Lot 70 (72 , 654 sf) Agency in Fee Agency Parcel
(b) Lot 69 (74, 627 sf) Walter in Fee Walter Parcel
(c) Lot 68 (75 , 870 sf) Segundo in Trust Segundo Parcel
Walter Leasehold
(d) Lot 67 (75 , 922 sf) Browne in Trust Browne Parcel
(e) Lot lb (79 , 609 sf) U. S . in Trust Post Office
Parcel
(f) Lot 2b (6) (15 , 220 sf) Hirsch in Fee Hirsch Parcel
The parcels described in (e) and (f) above are also sometimes
referred to as the "Accessory Area. "
In addition, the Agency owns a 5 . 7 acre parcel referred to as
the Prairie Schooner Parcel . This parcel is not a part of the Site
but will be a part of the transaction as described herein.
FS2\276\014084-"6\2071566.9 02/18/94 -5-
4 . Acquisition Process . Except as specifically described
below, the acquisition process shall be as provided in this section
and the procedures herein shall be utilized for each of the
acquisitions described below. The purchase price for the Agency,
Walter, and Prairie Schooner Parcels shall be established by
appraisal . Appraisals for several of the parcels have been or are
being prepared by Jack Strobel, MAI . If the other party disagrees
with the appraisal, it may commission its own appraisal . If the
resulting appraisal is no more than 10 percent different from the
original appraisal , the parties shall split the difference . If the
difference is greater, the two appraisers shall select a third
appraiser, and if the appraisers cannot reach mutual agreement, the
price shall be the average of the two closest appraisals, with the
parties splitting the cost of the third appraiser. The area of the
parcel shall be established by survey paid for by the Tribe, and
acreage shall be net exclusive of required dedications .
With respect to those parcels not owned by either party to the
MOU and which cannot be acquired by the Tribe, the Agency shall
undertake acquisition in accordance with all requirements of law,
including appraisal, written offers to acquire, negotiation, and, if
necessary, consideration of condemnation. The Agency will consult
with and keep informed the Tribe and Caesars during this process .
All owner participation and relocation rules and procedures shall be
followed. Although the Agency agrees to initiate this process and
to schedule a hearing on adoption of a Resolution of Necessity, if
required, the parties expressly agree that the Agency is not
obligated to adopt such a Resolution and shall have no liability to
the Tribe for its failure to take an action to condemn any parcel .
In such event, the parties agree to investigate whether other
adjacent parcels are suitable for acquisition, so the transaction
can continue, but if none can be found, the parties will unwind the
transaction and attempt to restore each party to the position in
which it started by reconveying land and repaying all funds .
In general, all direct acquisition costs (e .g. , real estate
purchase price, relocation, escrow, title, appraisal) will be
advanced by the Tribe, other than for the Hirsch Parcel and Post
Office Parcels (e) and (f) , which will be advanced by the City
including for the attorney fees incurred in condemnation, according
to a budget approved in advance by the Tribe except as provided in
paragraph 5 . c. Except as otherwise agreed by the parties, the limit
of the Public Entities, financial contribution shall be their
absorption of their internal and staff costs as described in the
paragraph following paragraph 2 .b . above, plus the Public Entities,
contribution of the proceeds from the sale of the Agency and Prairie
Schooner Parcels, as provided herein. All parcels shall be conveyed
pursuant to purchase/sale agreements including escrow instructions
with standard terms and conditions, including contingencies for
title, soils, and toxic conditions . Title shall be taken in the
name of the United States in Trust for the Tribe or as the Tribe may
designate . As the Tribe is responsible for certain costs, as
specified herein, it shall be a condition that the Tribe approve any
contingency which could involve cost in excess of the amount
1:52\276\UI4II84-0006\2071566.9 02/18/94 -6-
provided for that cost in the approved budget . The purchase price
will be paid at closing. The parties further agree to enter into a
formal disposition and development agreement and hold a public
hearing thereon pursuant to Health and Safety Code § 33433 .
It is contemplated that all parcels close concurrently, and
this shall be a condition of the sale. However, in the event one or
more of the parcels must be condemned, the Agency will need funds to
obtain an order for prejudgment possession ( "OIP" ) prior to being
able to deliver title insurance . The parties therefore agree that
(i) any parcel may be conveyed with a right of reverter in the event
all parcels are not acquired or the Casino is not timely commenced,
(ii) the Tribe will deliver any funds necessary to obtain an OIP,
and (iii) the Agency will work with the title company so that title
insurance can be obtained based upon the OIP, and shall provide any
necessary indemnity.
Any condemnation action entails significant risks including
that the Agency will lose the right to take because, in the opinion
of the court, proper procedures have not been followed, or the
judgment may be for significantly more money than the Agency' s
appraisal . In addition, the condemnee can recover attorneys fees in
the event they prevail in the action. The Agency can also be liable
for attorneys fees from abandoning the action. The Tribe is aware
of these risks . As provided for in this Memorandum, the Tribe
agrees to be responsible for the costs of the judgment in
condemnation, including, if required by law, the condemnee' s
attorney fees, if awarded, but retains the right to instruct the
Agency to abandon the action, but in such event shall reimburse the
Agency for the costs it incurs in abandoning the action. Given the
sovereign immunity of the Tribe, these obligations shall be secured
by an appropriate mechanism to be agreed upon by the parties .
5 . Accruisition of Specific Parcels :
a. Agency Parcel . The Agency will sell all its right,
title, and interest in and to the Agency Parcel to the Tribe or its
designee, at a price expected to be approximately $8/net square
foot .
b. Walter Parcel . The Walter Family Partnership
( "Walter" ) plans to sell all of its right, title, and interest in
and to the Walter and Segundo Parcels to the Tribe or its designee .
Walter shall have a right to make the receipt of a parking variance
from City a condition of closing.
C . Hirsch and Post Office Parcels . With the funds which
the Agency receives for its sale of the Agency Parcel and the
western approximately 4 acres of the Prairie Schooner Parcel, the
Agency will attempt to purchase the Hirsch Parcel fronting on Indian
Avenue as well as the Post Office Parcel . If the Hirsch and Post
Office Parcels cannot be acquired voluntarily, the Agency will
consider acquiring them by exercise of the power of eminent domain
as described above. However, the Tribe recognizes the ability to
PS2\276\014084-W06\2071566.9 02/18/94 -7-
condemn Federal property may be limited. The Agency will pay all
sale proceeds paid for the above portion of the Prairie Schooner
Parcel and the Agency Parcel, toward the purchase of the Hirsch and
Post Office Parcels . If the cost of acquiring these parcels by
voluntary purchase or by exercise of the power of eminent domain
exceeds the Agency' s sale proceeds from the sale of the Agency and
Prairie Schooner Parcels, the Tribe will either advance up to
$500 , 000 in additional funds or will reimburse the City for up to
this amount . If the costs of acquisition exceed the amount of the
proceeds of the sale of the Agency and Prairie Schooner Parcels, as
supplemented by the $500, 000, the parties shall meet and confer
concerning responsibility for payment therefore . The Tribe will
actively assist the City in negotiations with the U.S . Postal
Service and will consider taking steps in conjunction with the
Agency to guarantee that the cost to the U.S . Postal Service of
substitute parking will not exceed its present cost for parking on
the Post Office Parcel . on the other hand, if the acquisition cost
of the Hirsch and Post Office Parcels is less than the proceeds of
the sale of the Agency Parcel and the above western portion of the
Prairie Schooner Parcel, any remaining balance will be used for
purposes which the City finds will directly improve or otherwise
benefit the Project, including without limitation, parking
enhancement, provided that the Tribe agrees that the expenditure
will directly benefit the Project .
d. Prairie Schooner Parcel . The Agency agrees to sell
all of the Agency' s right, title, and interest in and to the western
approximately 4 acres of the Prairie Schooner Parcel, (the "Walter
Portion" ) to the Tribe at a price now expected to be approximately
$6/net square foot, again based on such an appraisal report as
described above . The City shall, without charge, process a
subdivision map to divide the parcel consistent with this MOU. The
Tribe will convey the Walter Portion to Walter in exchange for the
Segundo Parcel and will reconstruct four tennis courts and a pro
shop on the Walter Portion. The net result of this transaction will
be that Walter will own the 4 western acres of the Prairie Schooner
Parcel and will have its four tennis courts and pro shop rebuilt
thereon. Walter may seek a parking variance which City agrees to
consider.
6 . Agreement to Negotiate With Walter Concerning Disposition
of Remainder of Prairie Schooner Parcel. The Agency intends
initially to use the 1 . 7 acre remainder of the Prairie Schooner
Parcel (the "Remainder Portion") for parking for the Convention
Center, but nothing herein shall be deemed a covenant restricting
the use of said Remainder Portion. The Agency agrees to enter into
an agreement to negotiate with Walter concerning the disposition of
the Remainder Portion. The Agency agrees to give Walter an
exclusive agreement to negotiate for the sale of the Remainder
Portion before selling the parcel to any other party. After said
exclusive period, the Agency shall be free to dispose of the
Remainder Portion to any other party, in accordance with law.
PS2\276\014084-0006\2071566.9 02/18/94 -8-
i •
7 . Conditions . The parties agree that there are major
contingencies not in control of either party which excuse
performance . They include but are not limited to:
a. The Public Entities In use of their discretion may
elect not to condemn, vacate streets, or take some
other action requiring a public hearing.
b. The Public Entities may not be able to acquire a
parcel, including the Post Office Parcel, due to
Federal sovereign immunity.
C . The Casino may not be timely commenced.
d. Costs of acquisition, including purchase, title,
soils, and/or condemnation costs may exceed the
budget, and the Tribe may elect not to pay them.
In such case, the parties shall meet to try and modify their
agreement to still accomplish the purposes of this MOU, but if that
cannot be accomplished, the parties will unwind the transaction with
each party being restored insofar as possible to their original
position by reconveying land and repaying all funds .
8 . Good Faith Amendment, Enforceability. For the reasons
previously stated, the parties cannot at this time enter into a
binding enforceable agreement . In addition, it is not now fully
possible to anticipate what issues will arise in the future
regarding property acquisition, siting, construction, and operation
of the Project . In addition, a number of further agreements are
required as referred to herein. The parties agree to work in a
spirit of partnership, and to cooperate in good faith to achieve the
purposes of this MOU. This MOU can be amended by the mutual
agreement of the parties .
It is further understood that due to its sovereign immunity,
the Tribe cannot be judicially compelled to abide by the terms of
this MOU or the subsequent agreements into which the parties may
enter. This is significant to the Agency as it contemplates selling
parcels with a right of reverter and undertaking condemnation
proceedings where the Agency can be liable for damages for not
seeing the action through to completion, including paying the
judgment .
Therefore, not being able to enforce reverter provisions or
compel payment of funds agreed to is a serious concern. Therefore,
the parties have agreed:
a . The Public Entities may seek a guarantee acceptable
to the City of the Tribe' s obligations by Caesars or
one of its subsidiaries . This may include title
temporarily passing to Caesars containing the rights
of reverter discussed above.
FS2\276\014084-M6\2071566.9 02/19/94 -9-
b. The subsequent agreements will be structured insofar
as possible to limit the risk to the Public Entities
by requiring the posting of security, payment of
deposits, and/or deferral of incurring of
obligations to minimize the financial exposure of
the Public Entities .
If one or all of these can be accomplished to the satisfaction
of the Public Entities, then the Public Entities will enter
agreements legally binding on them, otherwise they will retain the
same right not to be sued to enforce the terms of their agreements
as the Tribe retains .
9 . Cooperation Recrardina Scope of Gamincr. The Tribe and the
City both recognize that the economic value and effectiveness of the
Project for both the Tribe and the City depend largely on the scope
of gaming allowed under a compact for Class III gaming (other than
off-track wagering on horse races) between the Tribe and the State
of California. This issue is now the subject of both litigation and
negotiation. In order to provide the maximum possible scope of
gaming, the City will exert its own efforts, by way of lobbying and
other permissible contacts, with the California State Government' s
executive and legislative branches to induce them to execute and, if
necessary, approve such a compact with the Tribe which provides for
the broadest possible scope of gaming. The City will take such
steps in coordination with the Tribe to achieve maximum effect, and
FS2\276\014084-0006\2071566.9 02/18/94 -1 0-
will similarly support the approval of such a compact by the
Secretary of the Interior.
Dated: 1994 "TRIBE"
AGUA CALIENTE BAND
OF CAHUILLA INDIANS
Richard M. Milanovich,
Chairman, Tribal Council
APPROVED AS TO FORM:
�✓U � �il/Y4.s-
Art Bunce, Esq. , Tribal Attorney
Dated: Plat '� l 1994 11CITY11
ATTEST: CITY OF PALM SPRINGS
c
by: i r/�
City Clerk L oyd Maryanov, Aayor
APPROVED AS TO FORM:
RUTAN & TUCKER
APPROVFr PY THE CITY COUNCIL,
Br�S. NO.
David J. A hire, City Attorney ! 0
Dated: Z2- 1994 "AGENCY"
ATTEST: COMMUNITY REDEVELOPMENT
AGENCY OF THE CITY OF PALM
SPRINGS
\ by: Z,4.�
�
Asst. Secretary L yd Maryanov, Chairman
APPROVED AS TO FORM:
RUTAN & TUCKER
David J. eshire, Agency Counsel
AggN.y ZY RES. NO.
FS2\276\014084-0006\2071566.9 02/18/94 �7 C
EXHIBIT "A"
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PALM SPRINGS, CALIFORNIA
GAMING FACILITY PROJECT AREA
AGUA CALIENTE BAND OF CAMILLA INDIANS
REVISED 2/24/94
EXHIBIT B
Agency Parcel
Lot 70, Section 14, T.4S . , R A S . , S .B.B.M.
Walter Parcel
Lot 69 , Section 14, T.4S . , R AE . , S .B.B.M.
Segundo Parcel
Lot 68, Section 14, T.4S . , R AE . , S .B.B.M.
Prairie Schooner Parcel
Lots 7, 8, and 111, Section 14, T.4S . , R AE . , S .B .B .M.
Post Office
Lot lb, Section 14, T.4S . , R AE. , S .B.B.M.
Hirsch Parcel
APN 508-041-006, Section 14, T.4S . , R AE. , S .B.B.M.
FS2\276\014084-0006\2071566.9 02/18/94 -1 2-