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ATTY/AGR/SETTLEMENTS/2026/JUVA RETAIL RWC INC./JUVA RETAIL RWC INC. SETTLEMENT AGREEMENT <br />REV: 04-24-26 MI <br />Page 3 of 9 <br />L. On March 2, 2026, the City issued a notice of assessment to Permittee (“Notice of <br />Assessment”), a true and correct copy of which is attached hereto as Exhibit A. <br />M. On March 13, 2026, Permittee requested an administrative hearing to contest the <br />Notice of Assessment. <br />N. As partially documented above, disputes have arisen among Permittee, Purchaser, <br />and the City regarding Permittee’s obligations to pay unpaid taxes, penalties, and interest <br />(“Disputes”). Purchaser generally supports Permittee regarding the Disputes. <br />O. The Parties, wishing to avoid the uncertainties, delay, and expense of continuing <br />with the Disputes, including without limitation in administrative and or judicial proceedings, agree <br />to settle upon the following terms. <br />TERMS <br />In consideration of the Recitals set forth above, the terms and conditions of this Agreement <br />and other valuable consideration, the adequacy of which is hereby acknowledged, Permittee and <br />the City agree as follows: <br />1. Recitals: The foregoing Recitals are true and correct and incorporated herein. <br />2. Settlement Payment: <br />a. Amount: Permittee shall pay to the City, and the City shall accept, Two Hundred <br />Twelve Thousand Two Hundred Ninety-eight dollars and forty-seven cents ($212,298.47) <br />(“Settlement Payment”) in full settlement and compromise of the Disputes, and in release <br />and discharge of any and all claims and causes of action arising out of Permittee’s failure <br />to remit payment for the tax period spanning December 2023 through September 2025 <br />under the terms and conditions set forth in this Agreement. Settlement Payment shall be <br />made as follows: <br />i. Within five (5) business days of the City’s approval of this Agreement, <br />Permittee shall make an initial payment of Twelve Thousand Two Hundred <br />Ninety-eight dollars and forty-seven cents ($12,298.47). <br />ii. Thereafter, on a monthly basis, Permittee shall make additional payments in the <br />amount of Twelve Thousand Five Hundred dollars ($12,500) for a period of <br />sixteen (16) months until the remaining Two Hundred Thousand dollars <br />($200,000.00) is repaid in full. <br />iii. Permittee shall deliver payments to the City’s Finance Department through <br />check, cashier’s check, money order, or cash. <br />b. Penalties and Interest for Late- or Non-payment: Permittee shall be subject to <br />penalties and interest for late payment. A penalty of ten percent (10%) of the amount owed <br />will be assessed for late payments. An additional penalty of ten percent (10%) shall be <br />imposed for each subsequent ten (10) day period the amount owed remains unpaid.