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SETTLEMENT AGREEMENT BETWEEN <br />ALISON MADDEN AND THE CITY OF REDWOOD CITY <br />This Settlement Agreement ("Agreement') is entered into as of July 25, 2022 ("Effective <br />Date") by and between Alison Madden ("Tenant') and the City of Redwood City (the "City"). <br />Tenant and the City are each referred to individually as a "Party" and collectively as the "Parties." <br />RECITALS <br />This Agreement is made with reference to the following facts and circumstances <br />("Recitals"). <br />A. The City serves as a trustee for state public trust lands on which Docktown Marina <br />("Docktown") is located, on and along Redwood Creek. <br />B. Beginning in or around the 1960s, individuals rented slips at Docktown, some for <br />residential use and others for non-residential use, e.g., recreational use. <br />C. In or around 2013, Tenant and the City entered into a written rental agreement that <br />authorized Tenant to dock a specified and identified vessel ("Inferno') in a designated slip <br />(no. 26) at Docktown for residential purposes. <br />D. In or around April 2019, Tenant and the City also entered into a berthing license <br />agreement by which Tenant secured; a right to dock another specified and identified vessel <br />("Bohemia") in a designated slip (no. 52) for non-residential purposes. <br />E. In or around late May 2022, Tenant moved another vessel ("Grace") into <br />Docktown, which Tenant docked in al slip at Docktown without permission from the City, and <br />which the City notified Tenant in June 2022 that she is obligated to move out of Docktown. <br />F. As used in this Agreement, "Premises" means and includes any and all slips or <br />other property at Docktown at which Tenant has docked any vessel (e.g., Inferno, Bohemia, and/or <br />Grace) and/or for which Tenant has claimed any rights to ownership, use, occupation, or <br />possession. <br />G. On December 12, 2016, the City Council adopted Resolution No. 15550, which <br />(i) directed the City Manager to terminate all residential rental agreements at Docktown (but not <br />non-residential rental agreements), and (ii) approved the Docktown Plan attached thereto to <br />provide relocation assistance and benefits to qualified residents of Docktown, not under the <br />California Relocation Assistance Law (Gov. Code § 7260 et seq.) ("CRAL") or federal law. <br />H. In or around June 2018, the City gave Tenant notice terminating her written rental <br />agreement for Inferno and her residential tenancy at Docktown. <br />I. Tenant has asserted she has a right to continue residing at Docktown, to receive <br />relocation assistance and benefits under the ORAL, to just compensation for inverse <br />condemnation, and/or for other legal or equitable relief. The City has asserted Tenant has no such <br />rights. <br />ATTY/AGR/SETTLEMENTS/SETTLEMENT AGREEMENT -ALISON MADDEN <br />REV: 07-21-22 VR <br />Page 1 of 13 <br />