HomeMy WebLinkAbout09/03/2024 07.J. Resolution authorizing the City of Yakima to consent to a conditional settlement agreement entered into by Cities Insurance Association of Washington (CIAW) and Munich Reinsurance to resolve and settle the lawsuit brought by Ricky Garcia i4
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BUSINESS OF THE CITY COUNCIL
YAKIMA, WASHINGTON
AGENDA STATEMENT
Item No. 7.J.
For Meeting of: September 3, 2024
ITEM TITLE: Resolution authorizing the City of Yakima to consent to a conditional
settlement agreement entered into by Cities Insurance Association of
Washington (CIAW) and Munich Reinsurance to resolve and settle the
lawsuit brought by Ricky Garcia
SUBMITTED BY: Ryan Bleek, Senior Assistant City Attorney
SUMMARY EXPLANATION:
This matter is on for consideration of a Resolution consenting to a settlement agreement resolving the
lawsuit filed by Ricky C. Garcia on September 13, 2022 in Yakima County Superior Court Case No. 22-2-
01946-39 entitled Ricky C. Garcia v. City of Yakima and Earl R. Guerin and Jane Doe Guerin. The
settlement would resolve all claims by the plaintiff related to a vehicle collision which occurred on
October 7, 2019 between his vehicle and a vehicle driven by a City of Yakima employee.
The claims against the City of Yakima and Earl Guerin were settled by the City's risk pool and insurer,
CIAW and Munich Reinsurance, on August 21, 2024, subject to the approval of the settlement by the
Yakima City Council. The amount of the settlement is $450,000. The City of Yakima has met its
deductible for this claim, so no additional funds will be paid by the City of Yakima towards the settlement.
ITEM BUDGETED: Yes
STRATEGIC PRIORITY 24-25: N/A
RECOMMENDATION: Adopt Resolution.
ATTACHMENTS:
Res-Settlement.docx
CR 2A Settlement Agreement.pdf
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RESOLUTION NO. R-2024-
A RESOLUTION authorizing the City of Yakima to consent to a conditional settlement
agreement entered into by Cities Insurance Association of Washington
("CIAW") and Munich Reinsurance to resolve and settle the lawsuit brought
by Ricky Garcia
WHEREAS, on September 13, 2022, a lawsuit was filed in Yakima County Superior Court
Case No. 22-2-01946-39 entitled Ricky C. Garcia v. City of Yakima and Earl R. Guerin and Jane
Doe Guerin; and
WHEREAS, a settlement was reached between CIAW and Munich Reinsurance and the
plaintiffs in the amount of$450,000 to resolve and conclude all claims in the matter; and
WHEREAS, plaintiff agreed to execute a Release agreement upon approval of the
proposed settlement by the Yakima City Council; and
WHEREAS, the City of Yakima has met its deductible for the matter, and all settlement
proceeds will be paid by CIAW and Munich Reinsurance; and
WHEREAS, the City Council of the City of Yakima deems it to be in the interest of the City
to authorize the City Manager to consent to a settlement entered into by CIAW and the plaintiff to
resolve and conclude the lawsuit; now, therefore,
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF YAKIMA:
The City of Yakima consents to the settlement entered into by CIAW and Munich
Reinsurance to resolve and settle the lawsuit brought by Ricky C. Garcia. The City Manager is
hereby authorized to execute all documents necessary to conclude settlement as consistent with
this Resolution.
ADOPTED BY THE CITY COUNCIL this 3rd day of September, 2024.
ATTEST: Patricia Byers, Mayor
Rosalinda Ibarra, City Clerk
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CR 2A SETTLEMENT AGREEMENT
Ricky C. Garcia v.City of Yakima and Earl Guerin
August 21,2024
This memorandum represents the agreement to settle all claims by Ricky C. Garcia ("plaintiff') against
City of Yakima,Earl Guerin,and the employees,agents,and insurers of each("defendants")on August 21,
2024, subject to the following terms:
1. The agreed total amount of settlement to plaintiff is $450,000.00 (Four Hundred Fifty Thousand
Dollars)paid on behalf of the defendants. This settlement is subject to approval by the Yakima
City Council,which is anticipated to occur on September 3,2024.
2. Such settlement payment is conditioned upon a full release of all claims brought or that could
have been brought by plaintiff against the defendants arising out of a motor vehicle accident
occurring on or about October 7, 2019, including all claims brought or that could have been
brought in litigation filed under Yakima County cause no.22-2-01946-39.
3. Defense counsel will provide plaintiffs counsel with a final,complete settlement agreement and
release for signature by plaintiff. Such final settlement agreement shall contain hold harmless
and indemnity language for any and all liens asserted.
4 Plaintiffs counsel shall provide defense counsel with a W9 containing tax id information and
payee information. The settlement shall be paid within 45 days of this agreement.
5. This settlement resolves any and all claims by plaintiff against defendants.
6. Upon payment of the settlement funds,the parties shall file a stipulated order dismissing the
underlying litigation with prejudice and without costs or fees.
7. The mediator shall act as fmal arbiter of any disputes associated with the fmal settlement
documentation. The parties intend that the mediator will consider confidential communications.
Other than as stated above, there are no additional representations or agreements of the parties. The
mediator's statements do not constitute legal advice to any party. The parties were represented by counsel
at the mediation.
August 21, 2024
Mediator: Christopher Anderson
Mariano Morales,counsel for plaintiff
Thomas Miller, counsel for defendants
128