Agmt22 Alison Madden - Laserfiche WebLink

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J. Two cases are pending in San Mateo County Superior Court with respect to the respective rights of Tenant and the City regarding multiple issues, including without limitation whether Tenant has any right to reside at Docktown and/or to compensation (e.g, relocation assistance under CRAL or for inverse condemnation): Fambrough v. City of Redwood City, Case No. 17CIV05387, a civil complaint in which Tenant is one of several plaintiffs ("Fambrough Case"); 2. City of Redwood City v. Alison Madden, Case No. 18UDL00816, an unlawful detainer proceeding ("Unlawful Detainer Case"). The Fambrough Case and Unlawful Detainer Case are collectively referred to as the "Litigation." K. In addition, Tenant has filed claims with the City pursuant to Government Code section 905 et seq., including without limitation on or about November 30, 2018 and March 15, 2022, in which Tenant has asserted, among other assertions, that the City has damaged Tenant in connection with Docktown-related matters ("Government Code Claims"). L. Tenant is an attorney (State Bar no. 172846) who represents herself in pro per, and is not represented by counsel. Tenant has done extensive legal work on her own behalf in connection with the matters discussed in these Recitals. M. Tenant is unable to move Inferno from Docktown, e.g., to another marina, and has decided to transfer ownership of Inferno to the City as part of this Agreement. Concurrently with execution of this Agreement, Tenant has executed and delivered to the City (a) a Bill of Sale in the form provided as Exhibit A attached hereto, which describes Inferno and conveys to the City all of Tenant's interest in and to Infemo free and clear of all recorded and unrecorded encumbrances, liens, assessments, leases, and taxes; and (b) a State of California Certificate of Ownership form releasing all interest in Inferno. N. Tenant desires to temporarily reside on Bohemia at Docktown through no later than November 14, 2022, and to move Bohemia, as well as any and all of her property, and to fully vacate herself, her son, any and all other family members, tenants, subtenants, licensees, guests, and/or invitees, and all of their personal belongings from Docktown no later than November 14, 2022. O. Tenant also desires promptly to move Grace out of Docktown, but has represented to the City that she is unable to do so prior to the Effective Date. P. Tenant and the City participated in a mediation with the Honorable James Lambden (Ret.) (through ADR Services, Inc.) on June 24, 2022, along with (i) other plaintiffs in the Fambrough Case and (ii) a plaintiff in another civil proceeding against the City in which the allegations concern that plaintiffs alleged right to reside at Docktown and/or to compensation (e.g., relocation assistance under CRAL and/or for damages), Sole v. City of Redwood City, San Mateo County Superior Court Case No. 17CIV04898 ("Sole Case"). The other plaintiffs in the Fambrough Case and the Sole Case are referred to herein, collectively, as the "Other Litigants". ATN/AGR/SETTLEMENTS/SETTLEMENT AGREEMENT -ALISON MADDEN REV: 07-21-22 VR Page 2 of 13