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08-1305Council File # (� ( 6 � Green Sheet # 3064095 RESOLUTION MINNESOTA ,- 2 WHEREAS, pursuant to Minn. Stat. § 117.0412, the Port Authority of the City of Saint Paul 3 requested authorization from the City of Saint Paul to acquire by eminent domain 1400 Jackson Street, 4 Saint Paul, Minnesota, property owned by Advance Shoring Company, on the basis that the property meets 5 the definition of a blighted or an environmentally contaminated azea as defined by Minn. Stat. § 117.025; 6 and 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 WHEREAS, on Wednesday, October 22, 2008 after the close of the public hearings on the Port Authority's request, City Council Member Lee Helgen expressed his desire that both the Port Authority and Advance Shoring figure out a creative means of reaching a resolution that works for both parties; and WHEREAS, the Port Authority and Advance Shoring and their counsel heard and have acted on Council Member Helgen's request and have entered into a Confidentiality Agreement, a copy of which has been provided to the City Council and is part of the council record; and WHEREAS, now that that the public hearing is closed and therefore under Minnesota Statute section 117.0412(2)(b) the City's decision whether to grant or deny the Port Authority's eminent domain authorization is scheduled for a decision on November 26, 2008; and WHEREAS, per the Confidentiality Agreement, boYh parties request that the City Councils' decision be laid over to no earlier than Wednesday, June 10, 2009, in order to provide both parties this time period for candid, constructive, and confidential discussions that both parties are hopeful can lead to a workable resolution for them both. 25 NOW, THEREFORE, PER THE TERMS OF THE CONFIDENTIALITY AGREEMENT, BE IT 26 RESOLVED THAT: 27 28 The Saint Paul City Council lays consideration of the Port Authority's request to acquire 1400 29 Jackson Street by eminent domain to Wednesday, June 10, 2009; be if further resolved that 30 31 32 33 34 35 36 37 The Port Authority's eminent domain authorization request will be decided by the City Council only upon receipt of a duly executed Port AuthoriYy resolution requesting that the Saint Paul City Council approve a resolution authorizing the Port Authority to acquire 1400 Jackson Street via eminent domain; if the Saint Paul City Council has not received such a resolution from the Port Authority by Wednesday, June 10, 2009, then the Port Authority's eminent domain authorization request will be deemed to have been wiYhdrawn; and, be it further resolved that as2ai.�s C�- ��oS 38 In the event the City Council receives a Port Authority resolution requesting eminent domain 39 authorization, then the City Council will place the eminent domain authorization action on for 40 consideration no eazlier than 30 days thereafter, but in any event no earlier than Wednesday, June 10, 2009. 41 Yeas Nays Absent Bostrom ;/ Carter ,i Harris �/ Helgen ,� Lantry ,/ Stark ,i Thune �/ lo � Requested by Department of: By: Approved by the Office of Financial Services ay: Approved by Ciry AtYOmey � Adopted by Council: Date ��,OIj,�C Approved by Mayor for Submission to Council Adoption Certified by Cow il Secretary By: By: �1P1 / Approve M y . ate � L�/ �� By: � � Green Sheet Green Sheet Green Sheet Green Sheet Green Sheet Green Sheet � n� Departmentl0ffice/Council: Date Initiated: co -�°°�� ,9_NO�-�$ Green Sheet NO: 3064095 ConWCt Person & Phone: Department Sent To Person InitiaVDate JenniferDunn o ovnca 0 6-8F>$� 1 ,Council De ar[mentDirector Au 2 i Clerk Ci Cierk Must Be on Council Agenda by (Date): Number 3 0 For 4 0 Routing Doc. Type: RESOLUTION �be� 5 � E-Document Required: Y Document Contact: Donna Sanders ConWCt Phone: 6-8653 Total # of Signature Pages _(Clip All Locations for Signature) Action Requested: Resolution requesting the Port Authority of the City of Saint Paul and Advance Shoring Company to continue discussion on potential acquisition of 1400 Jackson Street by the Port Authority. Recommendalions: Approve (A) or Reject (R): Personal Service Contrects Must Answer the Following Questions: Planning Commission 1. Has this person/firm ever worked under a contract for this department? CI8 Committee Yes No Civil Service Commission 2. Has this persoNfirm ever been a ciry employee? Yes No 3. Does this person/firm possess a skill not normally possessed by any current city employee? Yes No Explain all yes answers on separete sheet and attach to green sheet. Initiating Problem, Issues, Opportunity (Who, What, When, Where, Why): Ativantages It Approved: Disadvantages If Approved: Disadvantages If Not Approved: Total Amount of Transaction: CosURevenue Budgeted: Funding Source: Activity Number: Financia l Information: (Explain) November 19, 2008 8:59 AM Page 1 Q�-i3o5 CONFIDENTIALITY AGREEMENT The Port Authority of the City of Saint Paul ("the Port Authority") and Advance Shoring Company, Advance Specialties Company, and Advance Equipment Company (collectively referred to hereinafter as "Advance Shoring"), through their respective attomeys, agree to enter into the following Confidentiality Agreement ("Agreement"). Whereas, the Port Authority is seeking to acquire by the use of eminent domain the real property and improvements owned by Advance Shoring located at 1400 Jackson Street, St. Paul, Minnesota ("Advance Property"); Whereas, the Port Authority is confident that the use of eminent domain for the acquisition of the Advance Property is lawful and meets the standards and requirements of Minnesota Statutes and the United States and State of Minnesota Constitutions; Whereas, Advance Shoring objects to the use of eminent domain by the Port Authority and is confident that the use of eminent domain by the Port Authority is in violation of Minnesota Statutes and the United States and State of Minnesota Constitutions; Whereas, the Port Authority, in order to seek to acquire the Property by eminent domain, must first obtain approval from the City of St. Paul City Council pursuant to Minn. Stat. § 117.0412 ("Council Approval"); Whereas, Advance Shoring objects to the Council Approval and all efforts to acquire the Advance Property by the use of eminent domain; Whereas, the Port Authority has asked that Advance Shoring consider potential relocation sites to relocate the businesses located at the Advance Property; and Whereas, Advance Shoring and the Port Authority (collectively "Parties") enter into this Agreement as an interim effort to resolve their disputes prior to the requested Council Approval and prior to any litigation and in an effort to avoid the time and expense of litigation. Now, therefore, for good, valuable and sufficient consideration, the Parties agree as follows: 1. In an effort to resolve the dispute azising from and relating to the Port Authority's efforts to acquire the Advance Property by eminent domain, both parties agree that meaningful discussions are best conducted in an environment and conditions removed from the eminent domain process. Accordingly, counsel for the Port Authority will deliver a copy of this Confidentiality Agreement to the Saint Paul City Council with a request that the Port Authority's request for Council Approval be laid over until no earlier than June 10, 2009 (which is the next Wednesday, at least 30 days after the May 6, 2008 term expiration of this Agreement). 45413.v1 1 O�3-13�5 2. Confidential Information. During the period of time from November 17, 2008 through May 6, 2009, the Port AuthoriTy and Advance Shoring may exchange information in an effort to resolve their disputes. Subject to and pursuant to this paragraph and pazagraph 3 below, all such information shall be deemed confidential by and between the Parties, and as it relates to Advance Shoring, the information shall be deemed to be not public data, nonpublic data and private data on individuals under Minnesota's Governmental Data Practices Act, Minnesota Statutes Chapter 13. ("Confidential Information") During the discussions between the Parties, all such Confidential Information, whether written or verbal, beriveen the Port Authority and Advance Shoring, regarding the Port Authority's proposed acquisition of the Advance Property and the required relocation of the Advance Shoring's businesses in the event that the Parties are able to reach resolution shall be deemed to be confidential and subject to the terms of this Agreement. Both Parties shall keep the Confidential Information confidential as long as permitted by law, until the matter is fully settled, or the term of this Agreement is completed, whichever is earlier. No person receiving the Confidential Information shall, directly or indirectly, transfer, disclose, or communicate in any way the information to any person other than attorneys and their office associates, legal assistants, and stenographic and clerical employees; the employees of the parties, and outside independent persons (i.e., persons not currently or formerly employed by, consulting with, or otherwise associated with any party) who are retained by a party or its attorneys to furnish technical or expert services, or to provide assistance as mock jurors or focus group members or the like, and/or to give testimony in this action. Outside independent persons (i.e., persons not currently or formerly employed by, consulting with, or otherwise associated with any party) who are retained by a party or its attorneys to furnish technical or expert services shall sign the attached "Acknowledgment of Confidentiality" and upon execution a copy of the signed Acknowledgment will be provided to other party. 3. No Admission or Statement Aeainst Interest. No information provided in accordance with this Agreement (whether or not Confidential Information) shall be construed as a waiver of any claim or defense in any action between the parties or of any position as to discoverability or admissibility of evidence in any proceeding arising from or in any way related to the efforts by the Port Authority to acquire the Advance Property by eminent domain. All claims and defenses of tl�e parties under Minnesota Statutes Chapter 117, the Minnesota Constitution and the United States Constitution aze reserved. Advance Shoring and the Port Authority have divergent legal positions regarding the eminent domain law including but not iimited to reiocation rights and limitations. Both parties, however, may use the information obtained in their discussions to support their independent legal assertions, but any and all information provided by Advance Shoring and/or the Port Authority to the other daring these discussions shall not and cannot be deemed to be, asserted to be, claimed to be, or any matter presented in a 45413.v1 Z C� - /3� court of law by the party against the other as an admission, or a statement against interest. For instance, and not as a limitation, Advance Shoring asserts that as a matter of right and law it is entitled to relocation in the City of Saint Paul community and reserves the right to more specifically define its relocation rights under the law. The Port Authority asserts that as a matter of right and law the meaning of "community" is much broader. For these discussions, both the Port Authority and Advance Shoring may engage in discussions and provide information investigating and exploring many options that, in a court of law, could be deemed to support the other party's legal contention. No such discussions or exchanges of information are admissible in any proceeding as admissions or statements against interest. To restate, both parties may use the independently gathered information in a court of law, but cannot assert that the information is a concession or admission by the other on the legal issue in dispute. In particular, if the Port Authority elects to provide potential relocation sites to Advance Shoring that aze not located in the City of St. Paul and if Advance Shoring elects to evaluate such relocation sites, the evaluation thereof by Advance Shoring and/or the decision by Advance Shoring not to evaluate such relocation sites is not admissible in Court for any purpose. The Port Authority acknowledges that regardless of the discussions and the exchange of information, it remains Advance Shoring's position that the Port Authority may not acquire the Advance Properiy by condemnation and that, in the event that a Court does permit the Port Authority to acquire the Property by condemnation, any relocation site and the payment, therefore, must be for property located in the City of St. Paul. The above restriction on the use of such information in Court or any subsequent legal proceedings shall survive the termination of this Agreement. 4. Term. This Agreement shall remain in effect until either (i) Wednesday, May 6, 2009; or (ii) the parties enter into a fully executed settlement agreement. Until the termination of this Agreement, both parties shall keep the Confidential Information confidential as long as permitted by law. Upon the termination of this Agreement, the Parties are free to use the Confidential Information for any purposes. 5. Required Disclosures. Notwithstanding anything to the contrary, during the term of this Agreement if either party is required to disclose any Confidential Information to any governmental entity by law or pursuant to a subpoena, document production request, ALJ or judicial order, or other formal request lawfully compelling disclosure under applicable law, the party subject to the disclosure requirement will provide notice to the other party at least ten days prior to any such disclosure, and will produce only the Confidential Information the disclosing party in good faith believes is required to be disclosed and after taking reasonable actions to minimize the Confidential Information that is disclosed. 6. Governin¢ Law. This Agreement and all controversies arising from or relating to performance under this Agreement are subject to Minnesota Rules of Evidence 408 and its broadest application thereof and shall also be governed by and construed in accordance with the laws of the State of Minnesota. 45413 v1 3 d��os This Agreement is further subject to, and is to be interpreted consistently with, the provisions of Minn. Stat. Chapter 13 to the extent applicable. This Agreement does not, and cannot, ovemde the provisions of said Chapter 13. 7. Miscellaneous. This Agreement may be executed in one or more counterparts, each of which will constitute an original, and all of which together shall constitute one and the same agreement. Executed copies hereof may be delivered by facsimile or email and, upon receipt, shall be deemed originals and binding upon the parties hereto. 8. No Requirement of Disclosure. Notwithstanding anything to the contrary, this Agreement does not obligate any Party to disclose any information. During the period of this Agreement the parties agree not to seek publicity regazding the addresses or locations of potential relocation sites as set forth above. In the event that any inquiry is made regarding the addresses or locations of relocation sites during the term of the Agreement, the parties shall state words to the effect that "The Port Authority has decided to ask the Council to hold on further action regarding this matter while the Port Authority provides Advance Shoring with possible relocation sites for Advance Shoring's consideration. Advance Shoring has agreed to evaluate these potential alternative sites as requested by the Port Authority." 9. During the period of this Agreement, the Port Authority further agrees that it will not propose to the City Council the use of eminent domain or engage in negotiations with a property owner that include the use of eminent domain to make available a possible relocation site for Advance Shoring. Howard A. Roston, Esq. Malkerson Gilliland Martin LLP 1900 US Bank Plaza, South Tower 220 South Sixth Street Minneapolis, MN 55402 Phone: 612-455-6655 Fax: 612-344-1414 har(a�mgmllp.com www.mgmllp.com asa� 3 vi q d� -�� Lee U. McGrath Jason A. Adkins Institute for Justice Minnesota Chapter 527 Marquette Avenue, #1600 Minneapolis, MN 55402-1330 Phone: (612) 435-3451 — ext. 203 Fax: (612)435-5875 lmc�rath(a�ii.org jadkinsCa��ij.o�r www.ij.or� Thaddeus R. Lightfoot The Environmental Law Group, Ltd. 133 First Avenue North Minneapolis, MN 55401 Direct Dial: 612-623-2363 Facsimile: 612-378-3737 EmaiL tliehtfoot(a�enviroiawgroup.com Website: www.envirolaw r�ou .p com 45413 v1 b8-� �5 Eric D. Larson Port Authority of the City of Saint Paul 1900 Landmazk Towers 345 St. Peter Street St. Paul, MN 55102 Phone: 651/224-5686 Fax: 651/223-5198 edlna�sppa.com wwwsppa.com Mazc J Manderscheid Briggs & Morgan 2200 IDS Center 80 South 8th Street Minneapolis, MN 55402 Direct: 612-977-8280 Fax:612-977-8650 mmanderscheidna brig�s.com www.bri�,gs.com 45413.v1 6 f �Rb l�, � �� t�� — 1,- Taso (kdk'�KS IKs��Llc, �'wfc��c.�,� s��rl�,rYvct�,rl�c.tf+6c�n Z. –�@4S � ��`�`) ��v ��x�v Grr�..�� 33 �'rs�l�v e� �7 ��5 SS �I 3. l-��.�'� CZa�fb �J �?'��(J � 1 �`b�Q jW i�c C� ?'�,�1� S$C L� f K�,L�n .�1-a�.� , 3s7D Zi � s v��d��s l� �,�, s5 _ � Zc� -� � �`2�.Gr��. � �n;s� �,,,�e. �u 3c�� Sa� 1`1R�g�� . � �r �$'7 c� � _ ( 4+ OfM�OcS. �QfLT�N j �av«1(�ti.E .7N0'ELfN� V�NO�44L�. �4•� $SO)� �], Vl'�� ,tV1S�- �`��l l �r��,�. � �Y}��,� �� s... �s � a �{-� �� t3� �� -��.�� « �,.i �, _ lQ,VV� � ��( ��t� `t�--, I,CJ ��` l/YYVtJ �S!�' . ,��„� `� cc�.c L�3'� L= Z zo�'C �%�r� L�t-h�� .��/ �S37Z � � � � 3 2eJ � �,�.a� �t _ ,L��-�:r L�t x S� t�� `G� ��- /o�Z ��' /�.� � _ M �" �� _ �� d� ��'��,.-�,' �.t� w�v � �� c�� " �� _ �'� e�� `�� Sr/��.—.lrr'�� ,; ��:�i�..,��.�,'��'��'� �� / .�'�<� ,� c t� t� !8 �`Z �l S sr, �wr E-�z-s E^r° �.c1! �'`z�oz.�3 � V��C.fn.L_ V l� �j i''°<�--' �_ 1� f'uelx cd owE Gt ✓� C� �. e �Ve�v ,�� m�or� Lc�� 5 �� 1 �i _ �2h� ��' .�l/ 5f h s�—st•v � t��.s`3"'Z/c t� N s�c��! � c�_�,�` S� �. �� j 6"��i �f �� _w��ic �� s ��G � � _ ,. ��-�EQ�P�I �i �`� CECI� `�'� l.� _ �� ,�r sS:�� _ �o��.�.�� .-�� ;� .S - �,�� , � �= � � �. �V� r�-"� ��- \� �\ �� , _ ___._ _ --- � � f l��1�5 � - -- � _ � - - _ _ !I,_�rP��cL�u��.1 _ U:P� . 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