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7.1.F. - Page 3 <br /> Standstill Agreement <br /> This Standstill Agreement is entered into effective as on January 13, 2014, by <br /> Laurel Way Joint Venture, Oded Haner, and Laurel Way Joint Venture C/O Oded Haner <br /> (collectively "LWJV") and the City of Redwood City, a municipal corporation ("City"), <br /> subject to the following terms and conditions: <br /> Recitals <br /> A. City has approved a planned development permit ("PD Permit") and <br /> environmental impact report ("EIR") for the development of a project proposed by LWJV <br /> (the "Project"). <br /> B. Both City and LWJV have been made parties to litigation brought by an <br /> unincorporated association named Save Laurel Way ("SLW") filed in San Mateo Superior <br /> Court, No. 526753 (the "Action"). The Action challenges the validity of both the PD <br /> Permit and the EIR. <br /> C. LWJV contends that the conditions imposed by the City on the PD Permit <br /> as to house size are so onerous as to constitute a "taking"under federal and state constitu- <br /> tions and the doctrine of inverse condemnation, and that the City is required to compensate <br /> LWJV and the property owners who comprise LWJV (collectively, the "Lot Owners") for <br /> the "taking." However, if SLW should prevail in the Action, LWJV's claim for a "taking" <br /> may be found to not have been "ripe" for determination and, therefore, may be procedur- <br /> ally invalid, causing a multiplicity of litigation. <br /> D. Accordingly, the parties believe it is in their best interests to enter into this <br /> Agreement to avoid asserting, prosecuting, or defending claims against one another during <br /> {HANR:4218:WRW:H0172278.RTF.3} <br /> REV:03-28-14 PT <br /> ATTY/AG R/2014.041/STANDSTILL AG REE M ENT—LAUREL WAY <br /> Page 1 of 4 <br />