HomeMy WebLinkAbout06-73.doc
FEBRUARY 28, 2006
06-73
RESOLUTION
(CARRIED 6-1
LOST
LAID OVER
WITHDRAWN
PURPOSE:
APPROVE AGREEMENT WITH STATE OF WISCONSIN AND
DECADE'S I PIONEER INN PROPERTY
INITIATED BY:
DEPARTMENT OF COMMUNITY DEVELOPMENT
BE IT RESOLVED by the Common Council of the City of Oshkosh that the
Stipulation and Settlement Agreement between the State of Wisconsin, Decade's and
the City of Oshkosh regarding construction of a new condo-hotel development on the
former Pioneer Inn property and the City's development of a public trail and riverwalk
related improvements on said property, is hereby approved and the proper City officials
are hereby authorized to execute and deliver the agreement in substantially the same
form as on file at the City Clerk's Office, any changes in the execution copy being
deemed approved by their respective signatures, and said City officials are authorized
and directed to take those steps necessary to implement the terms and conditions of the
Agreement.
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December 20, 2005
STIPULATION AND SETTLEMENT AGREEMENT
THIS AGREEMENT is made this - day of December 2005, by and among, The State of
Wisconsin Board of Commissioners of Public Lands ("BCPL"), the Wisconsin Department of
Natural Resources ("DNR"), the City of Oshkosh (the "City") and Decade'sMonthly Income and
Appreciation Fund, a Limited Partnership ("Decade's").
RECITALS
A.
Decade's owns certain lands located in the City of Oshkosh (the "Property") shown
on the attached Exhibit A which is incorporated herein by reference. BCPL currently leases to
Decade's, as successor Lessee, certain lands on and adjacent to the Property pursuant to leases
originally executed in 1964 and 1969 (the "Original Leases"). The Origin;:ù Leases '?'Ïth subsequent
amendments are attached hereto as Exhibits B and C. DNR a;nâ a previous lessee entered into a
Stipulation Agreement in 1998 (the "1998 Stipulation"). A portion of the lands subject to the
Original Leases (shown in yellow and blue on Exhibit A) w~ under water at the time the Original
Leases. were executed and such submerged lands were s:ubsequently filled. A portion of the
footprint of the original Pioneer Inn extends onto the lands leased to Decade's by BCPL as shown
on Exhibit A. Decade's wants the State of Wisconsin to release any claims it may have with respect
to interests in property located landward of the original meander lines (as opposed to the ordinary
high water mark). Furthennore, Decade's asserts that it has a claim to fee title ownership of some
of the lands it currently leases. Decade's would like to fonnalize its rights with respect to such
property so that it can proceed with construction of improvements.
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B.
BCPL asserts that it holds interests in the lands marked in yellow and blue on
Exhibit A in trust for the State of Wisconsin as submerged lands. In recognition of the difficulties
in defining the historical ordinary high water mark on the property, BCPL is willing to use the
original meander lines as the dividing lines between fee-owned land and lands subject to the New
Lease ("Leased Lands"). Furthennore, BCPL is willing to lease land to Decade's pursuant to its
. statutory authority under Wis. Stat. Section 24.39(4)(a)(1) "for the improvement of navigation or
for the improvement or construction of harbor facilities..."
C.
The City has established a TIP district that includes the Pioneer Inn and the
surrounding land. The City wants to facilitate the redevelopment of the Property as a key financial
component of the TIP district and as a way to draw people to the waterfront in the City. The City
plans to construct a public walkway along the waterfront on portions of the Property and the Leased
Lands.
D.
The DNR and BCPL dispute Decade's right to rebuild thé Pioneer Inn on the portion
of its footprint that lies on land leased under the Original Leases or to develop any portion of the
lands leased under the Original Leases that lie waterward of the original meander lines except "for
the improvement of navigation or for the improvement or construction of harbor facilities."
Decade's disagrees with the DNR and BCPL and believes it has a right to rebuild the Pioneer Inn
on the portion of its footprint that lies on land leased under the Original Leases and to develop such
land in accordance with the terìns of the Original Leases.
E.
The parties desire to settle their dispute and enter into this Agreement to avoid
extended litigation. This is a settlement of disputed claims.
NOW, THEREFORE, the parties agree as follows:
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1.
Termination of Ori!!inal Leases. . The Original Leases between BCPL and
Decade's shall be tenninated and neither party shall have any continuing rights or responsibilities
under such Original Leases or any amendments thereto.
2.
Termination of 1998 Stipulation. The 1998 Stipulation in DNR Docket 3-
NE-98-0554UF between the DNR and Decade's predecessor in interest, Oly/Montclair, shall be
tenninated and neither DNRrior Decade's shall have any continuing rights or responsibilities under
the 1998 Stipulation.
3.
The New Lease. BCPL and Decade's shall enter into a new lease which is
attached hereto as Exhibit D and incorporated herein by reference (the "New Lease"). BCPL and
DNR acknowledge that Decade's is the riparian owner of the lands adjacent and contiguous to the
Leased Lands based upon the title commitment covering the Property attached hereto as Exhibit
and incørporated herein by reference. This Agreement does not affect Decade's riparian rights
associated with the Property to the extent they are exercised in accordance with the requirement for
enhanced public access described in Section 5 below.
4.
Reco!!nition of Meander Lines. The parties agree that the meander lines
established by the original Public Land Survey in 1835, as described in attached Exhibit A, shall
serve in place of the undetermined ordinary high water mark throughout the property gffected by
this Agreement, and shall serve as the line of division between fee-owned land which the State will
not claim an interest in and Leased Lands subject to the public trust. Nothing in this Agreement,
however, shall operate to waive Decade's obligations under Wis. Stat. Chapter 30, or other laws of
general application, to obtain pennits or authorizations ITom the State prior to placing fill or
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structures on, or dredging, any submerged lands, for purposes of this Agreement meaning property
actually covered by water, owned by Decade's.
5.
Enhanced Public Access. The Parties shall work cooperatively to provide
enhanced public access to and recreational uses of (i) the Leased Lands; (ii) certain parts of
Decade's Property to be used for a public walkway; and (iii) certain lands located south of Decade's
Property (including the breakwater area). The parties acknowledge that the present owner of those
certain lands located south of Decade's Property is not a party to this Agreement and no party to
this Agreement has an obligation to acquire additional.property interests to achieve such goal.
However, the City shall make a good- faith effort to acquire such property south ófDecade's
Property. The areas where enhanced public access and use are to be provided are shown on
attached Exhibit E. The enhanced public access shall include, at a minimum, provisions for
dedicated public parking South and Northwest of Decade's Property and the Leased Lands
(contingent upon the City's acquisition of a portion of the Canadian National Railroad right-of-way
in said area), provision of paths for pedestrian and bicycle travel, and physical access to the shore
for fishing, temporary boat and/or canoe tie ups and other recreational pursuits. The City has
submitted to the BCPL, DNR, and Decade's for approval, plans for the proposed physical facilities,
plans for the provision of public access and use of the area (including any proposed limitations on
public use or requirements precedent to use by the public), plans for future maintenance of the
facilities and the documents that assure the necessary property rights to maintain public access
(hereinafter "Plans/Documents"). Attached hereto as Exhibit "F" are the Plans/Documents which
are hereby approved by the Parties.
6.
Lakefront Easement to City, Construction o~. Decade's shall
provide an easement to the City for public ingress and egress and recreational use along the Leased
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Lands and also along a portion of the lakeftont Decade's owns in fee simple. This easement shall
allow the City to connect waterftontwalkways described in SectionS above between the Leased
Lands and the marina facilities. The easement area would start at the Northwestern point of the
Leased Lands and continue around the perimeter of Decade's Property to the marina facilities to the
South, in places traversing the Property owned by Decadè's. The easement area is marked in red on
Exhibit E. The City is responsible for constructing and maintaining the easement area. The City
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shall complete the necessary acquisition and installation of public facilities as soon as reasonably
possible, will commence construction of the walkway on the easement area at the same time
Decade's constructs improvements on the Property, will complete that portion ofthe walkway
proposed for the Property and Leased Lands 1?etween the connections for the two existing
pedestrian bridges depicted in Exhibit E by the time Decade's completes its improvements and the
balance ofthe walkway improvements will be completed by the City no later than 6 years from the
date of the commencement of construction. The easement provided by Decade's for ingress and
egress and recreational use as stated in this paragraph will limit the uses of the easement area solely
for these purposes and will specifically allow the City's law enforcement personnel to remove
individuals from the easement' area if they have been asked to leave the :Property or the Leased
Lands due to reasons that constitute disorderly conduct under state law or City ordinance or a
violation of the City's noise ordinance and the individual attempts to use the easement area to avoid
removal. The other parties shall, to the extent reasonably possible, provide support to assist the
City in the development of these facilities and shall not unreasonably refuse requests for state
permits that may be required for the walkway. The Parties and their assignees/successors will
execute and authorize any document necessary to extend the easements beyond the expiration of
the New Lease which may be necessary to allow the City to maintain the walkways which are the
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subject qfthis Agreement in perpetuity (the "Execution/Authorization Obligation"). The
Execution/Authorization Obligation shall run with the land which is subject to the walkway and
shall be binding upon all subsequent owners of such land.
7.
Agreement To Refrain From Certain Building On Leased Lands or
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Submerged Lands Subject to the Public Trust. The original Pioneer Inn was demolished in
2004 and Decade's will not rebuild the Pioneer Inn on any Leased Lands or submerged lands
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subject töthe public trust, and any improvements on the Leased Lands will be "for the
improvement of navigation or for the improvement or construction of harbor facilities..."
including the enhanced public access as more particularly described in paragraph 5 of this
Agreement. Decade's may undertake construction activities and place any improvements on the
Property landward of the original meander lines described in paragraph B above subject to
applicable local, state and federal regulations.
8.
Release of Claims by Decade's, Covenant Not to Sue. Decade's hereby
releases DNR and BCPL and their respective heirs, executors, administrators, legal representatives,
successors, and assigns, of and from all past and present claims, actions, obligations, costs,
expenses, compensation and demands which Decade's now has or may have against DNR and
BCPI:; arising under the Original Leases, the 1998 Stipulation, or the State's claim of interest in the
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Leased Lands, provided, however, that Decade's does not release its rights as a riparian in such
lands. Decade's covenants not to assert ownership of the Leased Lands and covenants not to sue
DNR, BCPL or the State of Wisconsin regarding ownership ofthe Leased Lands or the restrictions
on use of the Leased Lands stated in the New Lease. In accordance with this release, Decade's shall
immediately withdraw the Notice of Claim dated March 21,2005, and filed by Jeffrey Keierleber
as General Partner of Decade Companies and as President of Decade 80, Inc., the other General
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Partner of Decade Companies, as the General Partner of Decade's. Ifthere is a successful third
party challenge to this Agreement, the Findings pursuant to Section 30.11 by the DNR, or the New
Lease which results in a change to the boundaries of Decade's fee-owned uplands from the
boundaries described in paragraph 4 (hereinafter the "Successful Challenge"), the release stated in
this paragraph and the provisions of Paragraph 7 above will be null and void. Decade's may
reinstate its Notice of Claim within 60 days of the entry of judgment of the Successful Challenge. Such
reinstated Notice of Claim shall relate back to the dat~ of the original Notice of Claim, filed on March 21,
2005, and be subject to any and all defenses available to DNR and BCPL against the original Notice of
Claim. In that event, the Original Leases and the 1998 Stipulation will govern the rights of the
parties insofar as the Original Leases, or any agreed-upon extension, have not expired provided,
however, that BCPL, DNR and Decade's agree to execute any necessary agreements reasonably
required by the City to continue the Çity's walkway in the areas described in pars. 5 and 6 which
agreements become necessary as a result of the Successful Challenge.
9.
Release of Claims by BCPL and DNR. Covenant Not to Sue. BCPL and
DNR hereby release Decade's and its respective heirs, executors, admini~trators, legal
representatives,. successors, and assigns, ITom all past and present claims actions, obligations, costs,
expenses, compensation, and demands which BCPL or DNR now have or may have against
Decade's arising under the Original Leases, the 1998 Stipulation, or the State's claim of interest in
the lands covered by the Original Leases (that are not leased under the New Lease). BCPL and
DNR covenant not to assert ownership of such lands covered by the Original Leases (that are not
leased under the New Lease) and covenant not to sue Decade's regarding ownership or use of such
lands covered by the Original Leases (that are not leased under the New Lease). If there is a
Successful Challenge to this Agreement, the Findings pursuant to Section 30.11 by the DNR, or the
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New Lease which results in a change to the boundaries of Decade's fee-owned uplands from the
bound~ries described in paragraph 4, the release stated in this paragraph will be null and void. In
that event, the Original Leases and the 1998 Stipulation will govern the rights of the parties insofar
as the Original Leases, or any agreed-upon extension, have not expired provided, however, that
BCPL, DNR and Decade's agree to execute any necessary agreements reasonably required by the
City to continue the City's walkway in the areas described in pars. 5 and 6 which agreements
become necessary as a result of the Successful Challenge.
10.
No Admission or Precedent. Nothing contained in this Agreement shall be
used in any legal action other than in all enforcement action brought with respect to this
Agreement, the New Lease, the Findings Pursuant to Wisconsin Statutes Section 30.11 by the
DNR, or an action brought by a third party challenging this Agreement, the New Lease, or the
Findings Pursuant to Wisconsin Statutes Section 30.11 by the DNR, or if the releases stated in this
Agreement are nullified due to a Successful Challenge.
11.
Enforcement. Enforcement of this Agreement may be done by proceedings
at law or in equity against any party violating or attempting or threatening to violate any tenn or .
condition of this Agreement. Such proceedings may be brought to restrain or prevent any violation
or to óbtain any other permissible relief If a suit is brought to enforce this Agreement, the
prevailing party shall be entitled to recover its costs, including reasonable attorneys fees from the
nonprevailing party.
12.
Effective Date. This Agreement shall become effective upon the execution
by all of the undersigned.
13.
Miscellaneous.
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a.
Entire A!!reement/Amendment/Bindin!! Effect. This Agreement
contains the entire understanding by and among the parties regarding the settlement of all claims
arising under the Original Leases and the ownership of lands leased pursuant to the Original Leases
and ownership of the Leased Lands. No amendment, modification, or alteration of the terms ofthis
Agreement shall be binding unless it is in writing, dated subsequent to the date of this Agreement
and duly executed by all the parties. This Agreement shall be binding upon and inure to the benefit
of and be enforceable by the parties and their respective heirs, executors, administrators, legal
representatives, successors, and assigns.
b.
Counterparts. This Agreement may be executed in several
counterparts, each of which shall be deemed an original, but all of which shall constitute one and
the same instrument.
c.
No Waiver. Any failure of any party to comply with any obligation,
covenant, agreement, or condition herein may be waived only by written notice by the party
entitled to the perfonnance of such obligation, covenant, or agreement or who has the benefit of
such condition. However, the failure of any party at any time or times to require perfonnance of
any provision of this Agreement shall in no manner affect the right at a later time to enforce that
provision. No waiver by any party of any breach of any tenD contained in this Agreement, whether
by conduct or otherwise, in anyone or more instances, shall be deemed to be or construed as a
further or continuing waiver of any such breach or a waiver of any other tenD contained in this
Agreement.
d.
Governin!! Law/Jurisdiction/Service of Process. This Agreement
shall be governed by and construed in accordance with the laws of the State of Wisconsin. The
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parties agree that any action regarding this Agreement shall be brought in Winnebago County
Circuit Court and the parties further agree that such court has personal and subject matter
jurisdiction.
e.
Notices. Any notice given under this Agreement shall be in writing
and shall be delivered personally or sent by certified mail, postage prepaid to the address of the
party noted below:
To the BCPL:
To the DNR:
To the City:
To Decade's:
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f.
Captions/Gender and Number. The captions in this Agreement are
solely for convenient reference and shall not be deemed to affect the meaning or interpretation of
any article, section, or paragraph. All personal pronouns used in this Agreement shall include the
other gender whether used in the masculine or feminine or neuter gender, and the singular shall
include the plural whenever and as often as may be appropriate.
g.
Further Assurances. The parties agree that they shall deliver all
further documents and do all further acts necessary and desirable to consummate the transaction
contemplated by this Agreement.-
h.
No Presumption. This Agreement or any section of this Agreement
shall not be construed against any party due to the fact that this Agreement or any section of this
Agreement was drafted by or on behalf of said party.
1.
No Reliance On Other Representations. By their signatures below,
the parties to this Agreement hereby certify, each to the other, that prior to signing this Agreement,
each party has read this Agreement and fully understands its tenus. Each party executes this
Agreement without any reliance on any representations made by any other party, except for those
representations contained in this Agreement.
J.
Certification. Each individual executing this Agreement certifies
that he or she has authority to execute this document on behalf ofthe entity he or she is signing for.
k.
Severability. In the event that any portion of this Agreement should
be invalid under applicable law, then such portion is to be modified in the letter and spirit of this
Agreement, to the extent pennitted by applicable law so as to be rendered valid. Any portion of
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this Agreemen~ which is invalid under applicable law shall not render this Agreement or any part
thereof invalid, except as described in paragraphs 8 and 9, but such invalid portion shall be
inapplicable until the parties hereto have made appropriate changes in accordance with applicable
law to achieve the spirit of the invalid provisions.
CAUTION: READ THIS DOCUMENT COMPLETELY BEFORE SIGNING AS IT
AFFECTS LEGAL RIGHTS YOU MAY HAVE AND CONTAINS A RELEASE OF
. CLAIMS.
IN WITNESS WHEREOF, the parties hereto have executed this Agreement as ofthe date
written on page 1 of this Agreement.
Decade's:
Decade's Monthly Income and Appreciation Fund, a Limited Partnership
By:
, General Partner
City of Oshkosh
By:
Wisconsin Board of Commissioners of Public Lands
By:
Wisconsin Department of Natural Resources
By:
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"EXHIBITF"
Riverwalk System Maintenance Plan
As a looped riverwalk trail system is developed along the Fox River between
the new Wisconsin Street bridge and Lake Winnebago (including the trail to
be developed on and adjacent to the Pioneer Resort & Marina property), the
City of Oshkosh will provide for maintenance and upkeep of the facility.
Maintenance activities will include:
. Periodic cleaning and snow removal.
. Upkeep of installed landscaping and landscape features.
. Litter pickup and control.
. Repair of damage to walkway surfaces.
. Replacement of bulbs where decorative light standards are installed.