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HomeMy WebLinkAbout00319C - STEPTALL SETTLEMENT CANYON PROJECT Steptall , Inc. . Release & Settlement Agr. re: Canyon Development Proj AGREEMENT #319C A3262 R898, 9-1-93 RELEASE AND SETTLEMENT AGREEMENZ 1. PARTIES This Release and Settlement Agreement ("Agreement") is entered into by and between the following parties: A. Plaintiff and Petitioner Steptall, Inc. , a California corporation ("Steptall") ; B. Interested person Alain Salmea ("Salmea") ; C. Defendant and Respondent City of Palm Springs ("the City") ; D. Defendant and Respondent Palm Springs City Council ("the City Council") ; E. Defendant and Respondent Community Redevelopment Agency of the City of Palm Springs ("the Agency") (the City, the City Council and the Agency are sometimes collectively referred to herein as "the Palm Springs Defendants") ; and F. Real Party in Interest Canyon Development, a California general partnership ("Canyon") . 2 . RECITALS A. For several years Canyon has been in the process of developing a project known as the Canyon Park Resort & Spa ("the Project") , to be located at the southern edge of the City of Palm Springs. On or about December 28, 1990, Canyon filed its specific plan application for the Project with the City. B. On or about May 7 , 1991 Steptall sold to Canyon Steptall 's interest in lot 30 of Tract 16149, located within the City of Palm Springs. In connection with that sale by Steptall 930818 01310-01001 sas 0361976 2 to Canyon, on April 4 , 1991 Steptall executed two documents, a First Amendment To Deposit Receipt And Purchase Agreement ("First Amendment") , and a Release ("the Release") . Lot 30 of Tract 16149 is included within the Project. Salmea, president and sole director of Steptall, signed the First Amendment and the Release on behalf of Steptall. C. On July 19, 1991, by Ordinance No. 1388 , the City Council adopted and approved the Redevelopment Plan for the Canyon Redevelopment Project Area ("the Redevelopment Plan") . D. On July 19 , 1991, by Resolution No. 17600, the City Council approved and adopted the Canyon Park Resort & Spa Specific Plan ("the Specific Plan") . E. On July 19, 1991, by Resolution No. 17599, the City Council amended its General Plan with reference to the Redevelopment Plan and the Specific Plan. F. The Steptall Complaint. (1) On or about August 19, 1991 Steptall filed, in the Riverside County Superior Court, a Complaint to Determine Validity of Proceeding; Declaratory and Injunctive Relief; Petition for Writ of Mandate, against the Palm Springs Defendants (erroneously naming the Agency as "the City of Palm Springs Redevelopment Agency") and Canyon, captioned Steptall . Inc. . a California corporation Plaintiff and Petitioner, v. All Persons Interested In The Matter Of The Redevelopment Plan For Cannon Redevelopment Project Area, etc. , et al. , Case No. Indio 64937, ("the Steptall Complaint") . The Steptall Complaint contained sixteen causes of action. The first thirteen causes of action 930818 C1310-01001 sas 0361976 2 — 2 sought to challenge the Redevelopment Plan under the Community Redevelopment Law as set forth in the California Health and Safety Code. The fourteenth cause of action challenged the environmental review process used in approving the Redevelopment Plan under the California Environmental Quality Act. The fifteenth and sixteenth causes of action challenged the City's General Plan and the Specific Plan for the Project. (2) On or about November 12 , 1991 the Palm Springs Defendants and Canyon separately answered the Steptall Complaint and denied its material allegations. (3) On or about January 3 , 1992 the Court granted the motion of the Palm Springs Defendants, which was joined in by Canyon, for judgment on the pleadings in their favor as to the first through fourteenth causes of action of the Steptall Complaint, and dismissed those causes of action. (4) After the court' s determination of a special defense based upon the Release and a covenant not to sue contained in the First Amendment, the Court, on July 6, 1992, ruled that the fifteenth and sixteenth causes of action of the Steptall Complaint were barred. Accordingly, on August 3, 1992 , the Court entered judgment on the Steptall Complaint in favor of the Palm Springs Defendants and Canyon, and against Steptall, and the entire Steptall Complaint was ordered dismissed. (5) On September 25, 1992 the Court granted the motion of Canyon, which was joined in by the Palm Springs Defendants, to award and fix attorneys ' fees and costs, and ordered that Canyon and the Palm Springs Defendants were entitled 930818 C1310-01001 sas 0361976 2 - 3 - X to recover from Steptall the sum of $93 , 675.48 in attorneys' fees and costs. (6) On or about October 22 , 1992 Steptall filed a Notice of Appeal of the judgment entered in favor of Canyon and the Palm Springs Defendants. On or about February 23 , 1993 , Steptall filed Appellant' s Opening Brief in the Court of Appeal . The brief of Respondents Palm Springs Defendants and Canyon is due to be filed on or before July 23 , 1993 , unless a joint application of all parties for an extension of time is granted by the Court of Appeal. G. The Salmea Response In The Crocker Lawsuit (1) On September 13 , 1991, Jeremy Crocker, individually and as co-trustee of the Francis F. and Rosalie W. Crocker Trust, filed, in the Riverside County Superior Court, a Complaint To Determine Validity of Redevelopment Plan, For Declaratory and Injunctive Relief; Petition For Writ of Mandate, against Canyon, the City and the Agency, captioned Jeremy Crocker, Individually And As Co-Trustee Of The Francis F. And Rosalie W. Crocker Trust, Plaintiff and Petitioner, vs Community Redevelopment Agency of the City of Palm Springs, etc. , et al. , Case No. Indio 65118 ("the Crocker Complaint") . The first thirteen causes of action of the Crocker Complaint sought to challenge the Redevelopment Plan under the Community Redevelopment Law as set forth in the California Health and Safety Code. The fourteenth and fifteenth causes of action challenged the City's General Plan and the Specific Plan for the Project. 930818 C1310-01001 sas 0361976 2 - 4 - (2) on or about November 27, 1991 the City and the Agency, on the one hand, and Canyon, on the other hand, separately answered the Crocker Complaint and denied its material allegations. The action initiated by the Crocker Complaint shall be referred to herein as "the Crocker Lawsuit" . (3) On or about November 27 , 1991 Salmea filed, as a pleading in the Crocker Lawsuit, purportedly pursuant to the provisions of California Code of Civil Procedure Section 863 , Response Of Interested Person To Complaint ("the Salmea Response") . The Salmea Response is virtually identical to the Crocker Complaint, in that the Salmea Response sets forth virtually the same fifteen causes of action as is set forth in the Crocker Complaint. The Salmea Response also seeks relief identical to that sought by the Crocker Complaint. (4) On or about December 27, 1991 the City and the Agency answered the Salmea Response and denied its material allegations. On or about January 2 , 1992 Canyon answered the Salmea Response and denied its material allegations. (5) On or about July 6, 1992 the Court granted the motion of Canyon, which was joined in by the City and the Agency, to dismiss the fourteenth and fifteenth causes of action of the Crocker Complaint and the Salmea Response. H. It is now the common and mutual desire of the parties hereto to end the litigation referred to in paragraphs 2F and 2G, as it relates to said parties, and to resolve without further litigation all claims, and all possible causes of action 930818 C1310-01001 sas 0361976 2 - 5 - that could be asserted by Steptall and Salmea against Canyon and the Palm Springs Defendants. 3 . TERMS. A. Steptall agrees to dismiss its appeal now pending, with prejudice. B. Salmea agrees to dismiss the Salmea Response in the Crocker Lawsuit, with prejudice. C. Steptall and Steptall 's attorneys, and Salmea and Salmea' s attorneys, shall do all things necessary and appropriate to effectuate the provisions of paragraphs 3A and 3B. D. Salmea, and any entity in which he has or may have any interest, direct or indirect, now or in the future, and Steptall, on its own behalf, and on behalf of its insurers, partners, predecessors, affiliates, subsidiaries, companies or entities owned or controlled by Steptall, now or in the future, and on behalf of its and their stockholders, partners, officers, directors, agents, attorneys and/or employees, both past and present, agree that they will not purchase or otherwise receive or obtain, directly or indirectly, any interest in any real or personal property located within the geographical boundaries of the Redevelopment Plan, the Project, or the Specific Plan in the City of Palm Springs. E. Canyon and the Palm Springs Defendants agree to waive and relinquish their right to collect from Steptall the attorneys' fees and costs ordered due them as set forth in paragraph 2F(5) . If a monetary judgment has been entered against 930818 C1310-01001 sas 0361976 2 — 6 - f Steptall, Canyon shall provide Steptall with an acknowledgement of satisfaction of that portion of the judgment. F. Canyon, the City, and the Agency agree to waive and relinquish any right they may have to recover attorneys ' fees and/or costs from Salmea in the Crocker Lawsuit. 4 . RELEASE AND COVENANT NOT TO SUE A. For and in consideration of the release herein contained, the agreements set forth in paragraphs 3A through 3F, inclusive, and for other valuable consideration, the receipt and sufficiency of which is hereby acknowledged, (1) Salmea, and any entity in which he has or may have any interest, direct or indirect, now or in the future, and Steptall, on its own behalf, and on behalf of Steptall 's insurers, partners, predecessors, affiliates, subsidiaries, entities owned or controlled by Steptall, now or in the future, directly or indirectly, and on behalf of its and their stockholders, partners, officers, directors, agents, attorneys and/or employees, past and present, hereby forever and fully release and discharge (a) Canyon and its affiliates, partners, insurers, predecessors, assigns, successors, heirs, officers, directors, agents, representatives, attorneys and/or employees, both past and present, and (b) the Palm Springs Defendants, individually and collectively, and any instrumentality, division, agency, body or department thereof, as well as any of 930818 C1310-01001 sas 0361976 2 — 7 — their insurers, officials, agents, representatives, attorneys and/or employees thereof, past and present, (2) From any and all sums of money, accounts, claims, :Liens, obligations, interests, demands, contracts, actions, debts, controversies, agreements, covenants, damages, losses, liabilities and causes of action, whatsoever, of whatever kind or nature, in law, equity, or otherwise, whether now known or unknown, suspected or unsuspected, which those persons and/or entities referred to in paragraph 4A(1) now own, hold, have or claim to own, hold or have, and any future injuries not now known, or which may later develop or be discovered, including the effects or consequences thereof and all causes of action thereof, (a) arising out of or related to the events which are the subject of the Steptall Complaint, and/or the Salmea Response, any and all matters alleged or referred to in the Steptall Complaint and/or the Salmea Response, or arising out of or related to any trans- actions between the parties, and/or (b) arising out of or related to the Redevelopment Plan, the Specific Plan, the City's General Plan, the Project, and any and all amendments and/or modifications to any or each of them, that now exist or that may exist in the future, as well as any past, present or future law, ordinance, resolution or the like of any governmental authority or body, including, but not limited to, the Palm Springs 930818 C1310-01001 sas 0361976 2 — 8 — Defendants, which affects, directly or indirectly, in whole or in part, Canyon' s development of the Project, and/or the Specific Plan, or which affects any other property, real or personal, or any interest therein, which Canyon may acquire or obtain, located in the City of Palm Springs, for the purpose of development as part of the Project pursuant to the Specific Plan, in its present form, or as modified or amended. (3) Salmea, and any entity in which he has or may have any interest, directly or indirectly, now or in the future, and Steptall, on its own behalf, and on behalf of Steptall ' s insurers, partners, predecessors, affiliates, subsidiaries, entities owned or controlled by Steptall, now or in the future, directly or indirectly, and on behalf of its and their stockholders, partners, officers, directors, agents, attorneys and/or employees, past and present, agree that they (a) will not seek any compensation, damages or other relief at law, in equity, or otherwise, from Canyon and/or the Palm Springs Defendants, whether by filing a lawsuit or through any other means, in connection with or related to the Redevelopment Plan, the City's General Plan, the Specific Plan, the Project, and/or any amendments or modifications thereto, and (b) will not become a party to, fund, or in any way support, any litigation and/or administrative proceeding which arises out of or relates to, or which seeks to challenge any aspect of, the Redevelopment Plan, the City's 930818 C1310-01001 sas 0361976 2 — 9 — • 0 General Plan, the Specific Plan, and/or the Project, in their present form, or as modified or amended anytime in the future, as well as any past, present or future law, ordinance, resolution, or the like of any governmental authority or body, including but not limited to the Palm Springs Defendants, which affects, directly or indirectly, Canyon' s development of the Project, and/or the Specific Plan, in whole or in part, in their present form, or as modified or amended anytime in the future, or which affects any other property, real or personal, or any interest therein, which Canyon may acquire or obtain, for the purpose of development as part of the Project pursuant to the Specific Plan, in its present form, or as modified or amended. B. Notwithstanding the provisions of paragraph 4A of this Agreement, Steptall is not precluded from asserting, by way of answer, any and all claims for fair market value, severance damages, or loss of good will, which it may have or be entitled to, in the event that the City and/or the Agency files an eminent domain action to take any portion of any real or personal property now owned by or hereinafter acquired by Steptall. Nor shall Steptall be precluded by the provisions of paragraph 4A of this Agreement from filing an action for inverse condemnation in the event that the City and/or the Agency take any action(s) in the future which might or could be claimed to give rise to a right to compensation in inverse condemnation as to any portion of real or personal property now owned or hereinafter acquired by 930818 C1310-01001 sas 0361976 2 - 10 - /V Steptall that is located outside the geographical boundaries of the Redevelopment Plan, the Project, or the Specific Plan in circumstances wherein the City and/or Agency fail to timely file an action in eminent domain. The parties to this Agreement expressly agree that any real property contained in that portion of the area commonly known as Andreas Pointe, described as Lots 1 through 40, inclusive of Tract No. 18087 as per the map recorded in Book 211, Pages 81 through 89, as amended per map recorded in Book 216, Pages 32 through 40, inclusive, of the Official Records of Riverside County, California, is not located within the geographical boundaries of the Redevelopment Plan, the Project, or the Specific Plan. The parties further expressly agree that Lots 2, 3 , 5, 7 or 17 of said Tract 18087 presently owned by Steptall are not included within the geographical boundaries of the Redevelopment Plan, Project and Specific Plan. The provisions of this paragraph shall not be construed to allow Steptall to raise any issue or matter, directly or indirectly, collaterally or otherwise, that relates to or is referred to in the provisions of paragraph 4A. Nor shall the provisions of this paragraph 4B be construed to allow Steptall to challenge the right of the City or Agency to exercise the right of eminent domain. C. Salmea and Steptall have informed Canyon and the Palm Springs Defendants that Salmea and Steptall have filed suit in the Riverside County Superior Court against the law firm of Best, Best & Krieger, and attorneys employed by that firm, as well as against the accounting firm of Brabo, Carlson & Cahill, 930818 C1310-01001 sas 0361976 2 — 11 - E and Michael Brabo, individually, with respect to services rendered by them, or which they failed to render, on behalf of Salmea and/or Steptall . The provisions of paragraph 4A are not intended to, and do not, affect that litigation, and are not intended to, and do not, release any claims which Salmea and/or Steptall now have, claim to have, or may have in the future against those parties with respect to any services rendered by them, or which they failed to render, on behalf of Salmea and/or Steptall . This paragraph is not intended to, and does not, suggest or imply that either Canyon or the Palm Springs Defendants have any opinion, one way or the other, as to the merits of that lawsuit, or as to the merits of any such claims. D. Paragraphs 4B and 4C constitute the sole exceptions to the provisions of paragraph 4A. E. This release and covenant not to sue does not extend to the obligations and covenants of this Agreement. F. Neither Steptall nor Salmea will receive any consideration of any kind for this Agreement other than as expressly provided for in this Agreement. 5. REPRESENTATIONS AND WARRANTIES In making and executing this Agreement, it is the express understanding of the parties hereto, and they do hereby represent, warrant and agree as follows: A. There is a risk that subsequent to the execution of this Agreement, Steptall and/or Salmea will incur or suffer loss, damage, or injury to person or property which is in some 930818 C1310-01001 sas 0361976 2 - 12 - way caused by or connected to the matters referred to hereinabove, but which is unknown or unanticipated at the time of execution of this Agreement. B. Steptall and Salmea do hereby assume the risks referred to in paragraph 5A hereof, and agree that this Agreement shall apply to all unknown or unanticipated results of the matters described hereinabove, as well as those known and anticipated, and, upon advice of legal counsel, Steptall and Salmea do hereby waive any and all rights under California Civil Code Section 1542 , which section has been explained to Steptall and to Salmea by their legal counsel, and which reads as follows: "A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM MUST HAVE MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR." This waiver is a material term of this Agreement, without which neither Canyon nor the Palm Springs Defendants would have given the consideration stated herein. C. This Agreement is the result of a compromise of disputed claims and shall never at any time for any purpose be considered as an admission of liability or responsibility on the part of any party. D. The advice of independent legal counsel has been obtained by Steptall and by Salmea prior to the execution of this Agreement. Steptall and Salmea, by placing their initials at the bottom of each page and by signing this Agreement, hereby warrant 930818 C1310-01001 sas 0361976 2 — 13 — that they have read and understand the provisions of this Agreement and hereby execute this Agreement voluntarily and with full knowledge of its significance, and with the express intention of effecting the extinguishment of any and all claims arising out of or connected with the matters specified herein. E. Steptall and Salmea represent and warrant that no portion of any claim, right, demand, action, or cause of action which they have or might have, arising out of the matters referred to herein, has been assigned or transferred to any other person, firm or corporation not a party to this Agreement, in any manner, including by way of subrogation or operation of law or otherwise. In the event that any claim, demand, or suit should be made or instituted against Canyon and/or the Palm Springs Defendants, or any of them, because of any such purported assignment, subrogation, or transfer, Steptall and/or Salmea agree to indemnify and hold harmless the other parties against such claim, suit, or demand and to pay and satisfy any such claim, suit, or demand, including necessary expenses of investigation, actual attorneys ' fees and costs. F. In making and executing this Agreement, Steptall and Salmea do not rely and have not relied upon any statement or representation, oral or written, made by any of the other parties with regard to any of the facts involved in any dispute or possible dispute between them, or with regard to any of their rights or asserted rights, or with regard to the advisability of making and executing this Agreement. 930818 C1310-01001 sas 0361976 2 - 14 G. Steptall and Salmea do hereby expressly assume the risk of any mistake of fact or that the true facts might be other or different from facts now known or believed to exist, and it is the express intention of Steptall and Salmea to forever settle, adjust, and compromise the claims raised by the Steptall Complaint, and by the Salmea Response and all other claims released herein, without regard to who may or may not have been correct in their respective understandings of the facts or the law relating thereto. H. Steptall and Salmea have made such investigation of the facts and the law pertaining to the matters described herein and this Agreement as they deem necessary, and Steptall and Salmea have not relied and do not rely on any promise or representation made by any of the other parties with respect to any such matters. I. Each of the parties hereto has read and understands the contents of this Agreement. J. This Agreement is made on behalf of, and shall be binding upon the heirs, administrators, executors, successors, and assigns of the respective parties hereto and any parent, subsidiary, or affiliated entity of each of such parties. K. This Agreement constitutes the entire agreement between Steptall and Salmea, on the one hand, and Canyon and the Palm Springs Defendants, on the other hand, pertaining to the subject matters hereof, and the final, complete and exclusive expression of the terms and conditions of their agreement. Any and all prior agreements, representations, negotiations and 930818 C1310-01001 sas 0361976 2 — 15 — t understandings, oral or written, express or implied, are hereby superseded and merged herein. L. The provisions of paragraph 4A may be pleaded as, and are a complete defense and bar to, any action or proceeding of any kind that may be taken by Steptall and/or Salmea against Canyon and/or the Palm Springs Defendants, or any of them, on any claim arising from or in connection with the matters referred to in this Agreement. M. In the event any lawsuit or other proceeding is brought by Steptall and/or Salmea, on the one hand, against Canyon and/or the Palm Springs Defendants, on the other hand, or by Canyon and/or the Palm Springs Defendants, on the one hand, against Steptall and/or Salmea, on the other hand, arising out of or related to the terms and provisions of this Agreement, the prevailing party shall be entitled to recover its reasonable attorneys' fees, costs and expenses incurred in connection therewith, including those incurred in enforcing any judgment. N. The parties hereto agree to execute any and all other documents and instruments in writing which may be reasonably necessary or proper to effectuate and carry out the purposes of this Agreement. O. This Agreement shall be governed by and construed in accordance with the laws of the State of California. P. This Agreement may be executed in two or more counterparts, each of which shall be deemed an original, but all of which shall constitute one and the same written agreement. 930818 C1310-01001 sag 0361976 2 — 16 — i Q. The Palm Springs Defendants and Canyon waive all rights as against Steptall and/or Salmea for attorneys ' fees and costs, except as expressly reserved herein. Steptall and Salmea waive all rights as against the Palm Springs Defendants and/or Canyon for attorneys ' fees and costs, except as expressly reserved herein. R. The subject headings of the paragraphs of this Agreement are included for purposes of convenience only, and shall not affect the construction or interpretation of any of the provisions of this Agreement. S. All parties, through their counsel, participated in the drafting of this Agreement, and all parties agree that any rule of construction that agreements are to be construed adverse to the drafter shall not apply herein. WHEREFORE, the parties hereto have executed this Agreement on the dates set forth opposite their respective signatures. This Agreement shall be deemed entered into as of 930818 C1310-01001 sas 0361976 2 — 17 — the date of the signing of this Agreement by the party who last signs it. STEPTALL, INC. Dated: August 1993 By Alain Salmea Its President ALAIN SALMEA Dated: August 1993 By Alain Salmea CANYON DEVELOPMENT Dated: August 3— 1993 By Its THE CITY OF PALM SPRINGS Dated: August 1993 By Its PALM SPRINGS CITY COUNCIL Dated: August 1993 By Its' [Signatures continue] 930818 C1310-01001 sas 0361976 2 - 18 - the date of the signing of this Agreement by the party who last signs it. STEPTALL, INC. Dated: August 1993 By Alain Salmea Its President ALAIN SALMEA Dated: August 1993 By Alain Salmea CANYON DEVELOPMENT Dated: August 3n 1993 By -zLe-� Its ATTEST: THE CITY OF PALM SPRINGS B _ ity Clerk Dated: Augtrst 1993 By �,Ctih� lCc ' Its Mayor ATTEST: PALM SPRINGS CITY COUNCIL By(f Cit Clerk A /�CLL ,Date—UT: ugus 3 By ?1� J Its Mayor [Signatures continue] 930818 C1310-01001 sas 0361976 2 the date of the signing of this Agreement by the party who last signs it. STEMv- IN a Dated: August c , 1993 ByAlain S almea Its President ALAIN SALMEA Dated: August , 1993 By Alain Salmea CANYON DEVELOPMENT Dated: August 1993 By Its THE CITY OF PALM SPRINGS Dated: August 1993 By Its PALM SPRINGS CITY COUNCIL Dated: August 1993 By Its [Signatures continue] 930818 C1310-01001 sas 0361976 2 — 18 — ATTEST: THE COMMUNITY REDEVELOPMENT AGENCY OF THE CITY OF ByJt_ o �A PALM SPRINGS Cit C rk� �J,J//JJ Dated: Aug ust _, 1993 By �/� f /' /G ��rb r✓ It Chairman APPROVED AS TO FORM AND CONTENT: CRANDALL & TRAVER Dated: August 1993 By Lynn Crandall Attorneys for Plaintiff/ Petitioner Steptall, Inc. and Interested Person Alain Salmea RICHARDS, WATSON & GERSHON A Professional Corporation Dated: August 1993 By Robert M. Goldfried Attorneys for Real Party In Interest Canyon Development RUTAN & TUCKER A Professional Corporation Dated: August 1993 By M. Kai , rine Jenson Attorneys for Defendants/ Respondents City of Palm Springs, Palm Springs City Council, and Community Redevelopment Agency of the City of Palm Springs 930818 C1310-01001 sas 0361976 2 — 19 — THE COMMUNITY REDEVELOPMENT AGENCY OF THE CITY OF PALM SPRINGS Dated: August 1993 By Its APPROVED AS TO FORM AND CONTENT: CRANDALL & TRAVER Dated: August -2-0 , 1993 By L n1 Crandall Attorneys for Plaintiff/ Petitioner Steptall, Inc. and Interested Person Alain Salmea RICHARDS, WATSON & GERSHON A Professional Corporation Dated: August 1993 By Robert M. Goldfried Attorneys for Real Party In Interest Canyon Development RUTAN & TUCKER A Professional Corporation Dated: August 1993 By M. Katherine Jenson Attorneys for Defendants/ Respondents City of Palm Springs, Palm Springs City Council, and Community Redevelopment Agency of the City of Palm Springs 930818 C1310-01001 sas 0361976 2 - 19 - THE COMMUNITY REDEVELOPMENT AGENCY OF THE CITY OF PALM SPRINGS Dated: August 1993 By Its APPROVED AS TO FORM AND CONTENT: CRANDALL & TRAVER Dated: August _, 1993 By Lynn Crandall Attorneys for Plaintiff/ Petitioner Steptall, Inc. and Interested Person Alain Salmea RICHARDS, WATSON & GERSHON A Professional Corporation Dated: August �© , 1993 By / /kT/Y' F�i L""`�- /// ° Robert M. Goldfri d Attorneys for Real Party In Interest Canyon Development RUTAN & TUCKER A Professional Corporation Dated: August 1993 By M. Katherine Jenson Attorneys for Defendants/ Respondents City of Palm Springs, Palm Springs City Council, and Community Redevelopment Agency of the City of Palm Springs 930818 C1310-01001 sas 0361976 2 — 19 —