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HomeMy WebLinkAbout2010/08/10 Item 4 CITY COUNCIL AGENDA STATEMENT '''-If,; .:$ ~ CITY OF .~ (HUlA VISTA August 10,2010, Item No.: ~ ITEM TITLE: PUBLIC HEARING: PCZ-08-04 Consideration of an application filed by SKK Realty, LLC-requesting a rezone from MHP-Exclusive Mobilehome Park to R3 Apartment Residential Zone, with a Precise Plan Modifying District. RESOLUTION: of the City Council of the City ofChula Vista finding that the applicant has complied with required provisions ofLUT Section 7.17 of the Chula Vista General Plan regarding an application to rezone property currently designated MHP (Exclusive Mobilehome Park) Zone. SUBMITTED BY: ORDINANCE: of City of Chula Vista amending the Zoning Map established by Section 19.18.010 to rezone one 4.35 acre parcel located at 701 D Street from MHP (Exclusive Mobilehome Park) Zone to R-3-P (Apartment Residential, Precise Plan) Zone. Assistant Cit; Mana"~evelopment Services Director REVIEWED BY: City Manage 4/5ths Vote: Yes X No BACKGROUND The vacant 4.35 acre project site was the former location of Jade Bay Mobile Lodge, a 76 space mobilehome park established in 1960 under Conditional Use Permit (C-59-1). At the time the park was established, the zoning for the property was R-3 (Apartment Residential). On November 28, '1978, the City Council established the MHP (Exclusive Mobilehome Park) Zone. On June II, 1980, the zoning for the project site was changed from R-3 to MHP in recognition of the existing Jade Bay Mobile Lodge. The mobilehome park remained until 2006. Following the conclusion of bankmptcy proceedings, which began in early 2006, the site was vacated. The applicant, SKK Reality LLC ("Applicant"), now wishes to rezone the property to the original R- 3 zoning designation for the property. This would allow for future development of a high- density, multi-family project. In addition, the applicant is requesting a "P" Precise Plan Modifying District also be added to the site (see Attachment 3). It should be noted that this item 4-1 Meeting Date: 8/1011 0 Page 2 was continued by staff from the City Council hearing of July 14, 2009 and subsequently put on hold at the request of the Applicant. ENVIRONMENTAL REVIEW The Development Services Director has reviewed the proposed project for compliance with the California Environmental Quality Act (CEQA) and has determined that the proposed rezone was adequately covered in previously adopted General Plan Update Final Environmental Impact Report, EIR 05-01. Thus, no further environmental review or documentation is necessary. RECOMMENDA nON That the City Council adopt the attached Draft City Council Resolution and Ordinance, based on the findings contained therein. BOARDS/COMMISSION RECOMMENDATION This item was heard by the Planning Commission on June 24, 2009. Issues raised by the public and the commissioners included the relocation of former tenants of the Jade Bay Mobilehome Park and that the requested rezone was not accompanied by a development proposal for the site. The Planning Commission voted (4-1-0-2) to recommend City Council approval of the project (see Attachment 8). DISCUSSION Project Site Characteristics: The 4.35 acre site is located within the urbanized area of Western Chula Vista. The site is located at the northwest corner of D Street and Woodlawn Avenue. The western portion of the site is located in proximity to Interstate 5 Freeway. Primary access to the site is currently provided directly from D Street. The existing site is relatively flat, and was previously occupied by a mobilehome park. The existing surrounding land uses include apartments to the north, single- and multi-family residential to the east and a mobilehome park to the south. To the west is the Interstate 5 Freeway. The following is a summary of existing uses and General Plan and Zoning designations. 4-2 Existin!!: Zon;n!!: and Land Uses Site General Plan RH-High Density Residential (18-27 dulac) North R1v1H Medium-High Residential (11-18 du/ac) RH-High Density Residential (18-27 du/ac) Rt\1H -Residential- Medium-High (11-18 du/acre) South East West Open Space Project Description: Meeting Date: 8/10/10 Page 3 Zoning MHP (Exclusive Mobilehome Park) Existing Land Use Vacant R-3 (Apartment Residential) Existing Apartments MHP (Exclusive Mobilehome Park) Existing Mobilehome Park R-3 (Apartment Residential) Existing Single and Multi-Family Residential Unzoned San Diego Trolley/Interstate 5 The project consists of rezoning a vacant 4.35 acre site formerly utilized for a 76 space mobile home park. No development project is proposed on the site at this time. The purpose of the rezone is to make the zoning consistent with the General Plan and to allow the site to be developed under the R-3 zoning designation. ANAL YSIS: Rezone The proposed rezoning of the property to R-3 is consistent with the 2005 General Plan land use designation of High Density Residential (RH) (18-27 du/ac). The zoning designation would in essence, revert back to the R-3 zoning designation that originally applied to the project site prior to MHP rezoning in 1980. Now that the site is vacant, the R-3 designation would be the most appropriate zoning to apply to the site since it is consistent with the existing General Plan designation. Since the original development of the mobilehome park, more housing types at a variety of income levels have been developed within Chula Vista and under the proposed R-3 zoning designation more such housing would be permitted to be developed. Land Use General Plan Consistency The site and surrounding neighborhood consists of a mixture of apartments to the north, single and multi-family residential to the east and an existing mobilehome park to the south. The General Plan land use designations are for Medium High density to the north and east (11-18 4-3 Meeting Date: 8/10110 Page 4 dulac) and High Density Residential (18-27 dulac) tor both the project site and the area immediately to the south. Objective-LUT 55 encourages redevelopment of E Street between Interstate 5 and Broadway with mixed use, especially near the E Street Trolley Station, and an emphasis on visitor-serving uses, with some office and multi-family residential. The project site is located within the E Street Visitor District Focus Area of the Interstate 5 Corridor District. Policy LUT 55.2 is "to provide for the development of High Density Residential multi.family housing north of visitor uses on E Street, taking advantage of the views to the Bayji'om and beyond." Since the site is now vacant, the applicant's request to change the zoning to R-3 would be appropriate, since it would be consistent with the General Plan designation for the site. No development is proposed at this time. Rezoning the property to R-3 would support the construction of new, multi-family development at the densities anticipated under the General Plan. This should benefit the neighborhood since future high-density development will provide an appropriate transition between the San Diego Trolley/Interstate 5 freeway to the west and medium-high density development to the east. Precise Plan Modifying District In order to allow future design flexibility and to enable the City to require enhanced design elements on the property, a Precise Plan Modifying District would be established. The precise plan would address the unique characteristics of the property in relationship to its surrounding area. Since no specific development is being proposed at this time, the current request is only to add the "P" modifier to the zoning designation. At the time an actual development project is submitted, precise plan standards would be proposed and adopted prior to approval of any development project entitlements. The "P" Precise Plan Modifying District ("P-modifier") Section 19.56.040 states that the purpose of the P-modifier is "to allow diversification in the spatial relationship of land uses, density, buildings, structures, landscaping and open spaces, as well as design review of architecture and signs through the adoption of specific conditions of approval. . . ." It is further provided in section 19.56.040 that "[w]ithin the boundaries of the P district, the location, height, size and setbacks of buildings or structures, open spaces, signs and densities indicated on the precise plan shall take precedence over the otherwise applicable regulations of the underlying zone. " Section 19.56.041 sets forth the circumstances under which the "P" modifier may be established for a parcel. Specifically, Section 19.56.041 describes four circumstances, at least one of which must be present, in order to consider the approval of a P-modifier. Three of these circumstances are substantiated below: The. subject property, or the neighborhood or area in which the property is located, is unique by virtue of topography, geological characteristics, access, configuration, traffic circulation or some social or historical situation. requiring special handling of the development on a precise plan basis. The proposed P-modifier will provide necessary safeguards so that at the time of future development of the site, consideration will be made of the unique characteristics of the site as well as its location and surroundings. Currently, the subject property is only accessible from two 4-4 Meeting Date: 8/10/10 Page 5 sides of the subject property, from Woodlawn Avenue and D Street. Due to proximity to the San Diego Trolley line/Interstate 5 freeway to the west, and existing development to the north, it would not be feasible to construct either public or private streets along these boundaries. Such limited access may pose some unique and significant challenges as far as routine ingress and egress, emergency access and general traffic circulation. Additionally, this could result in the bulk of housing having to be located within the eastern and southern portions of the site. The P modifier would allow flexibility in thc future to make modifications to development standards such as building setbacks in order to accommodate future on-site development proposals. Because no actual development is planned in conjunction with this rezone request, no actual precise plan guidelines are being requested at this time. The property or area in which the modifYing district is applied is an area adjacent and contiguous to a zone allowing different land uses. and the development of a precise plan will allow the area so designated to coexist between land usages which might otherwise prove incompatible. The proposed P-modifier will allow future development of the site to achieve greater compatibility with the existing surrounding land uses. Directly north of the project site, the land which is zoned R-3 ("Apartment Residential Zone") is developed primarily with apartments and other multi-family structures. To the east, although also designated R-3, contains a mixture of both single and multi-family development. To the south of the projcct site, the land, which is zoned MHP (Exclusive Mobilehome Park), is fully developed as an 85 unit mobilehome park. To the west of the project site, the land contains certain road improvements serving Interstate 5 and the right of way for the San Diego Trolley line. In light of the diversity of existing land uses surrounding the project site, staff believes that the application of the P-modifier to the project site will allow greater design control over the eventual development of the project site to insure compatiblity with the existing uses surrounding the project site. Due to the proximity of Interstate 5 to the west of the project site and. associated noise and air quality concerns, it may be beneficial to design a future project in such away that it is primarily oriented away from the freeway. The basic or underlying zone regulations do not allow the property owner and/or the city appropriate cuntrol or flexibility needed to achieve an efficient and proper relationship among the uses allowed in the adjacent zone. The existing development standards under the R-3 ("Apartment Residential Zone") may be insufficient with respect to providing the City with the "appropriate control or flexibility needed to achieve an efficient and proper relationship among the uses allowed in the adjacent zones." Application of the P-modifier can provide flexibility in setback requirements. This would allow for a development to achieve a greater separation from the Interstate 5 freeway to the west without reducing the overall amount of density which may be achieved. In this regard, it would help achieve the Chula Vista General Plan goal of providing higher density residential development in proximity to existing transit facilities. Specifically, policy LUT \.8 is to pursue higher density residential categories that are not being met within the City. In 4-5 Meeting Date: 8110/10 Page 6 addition, it would allow for additional design restrictions which will result in a better site design and layout. A rezone request is typically accompanied by a request for a particular development proposal for the property. In this particular case, however, no development project is being proposed. Thus, although a P-modifier is being requested for the zone, no accompanying precise plan guidelines or standards are being requested for approval at this time. Establishment of the P-modifier will provide future flexibility to establish development standards if necessary to accommodate the preferred site design. Compliance 'with lvfobile Home Park Closure Requirements and Overlay District Typically, a site containing a MHP zoning designation would contain an existing mobilehome park at the time of a request for change in land use or rezone. As a result, a request to rezone a property currently zoned MHP with an existing mobilehome park would be accompanied by documentation outlining compliance with both Chapter 9.40 of the Chula Vista Municipal Code (CVMe) as well as Section 32 of the Land Use and Transportation Element of the Chula Vista General Plan. Chapter 9.40 outlines the specific criteria that must be contained within a required relocation plan for residents of the existing mobilehome park. Such a plan would typically have to be approved prior to consideration of closure of the park and subsequent rezoning of the property. A Mobile Home Park Overlay District (MHPOD) described in Section 7.17 of the Land Use and Transportation Element was established in October 2006. The objective of this newly added Section was to ensure sufficient evaluation and response to the effects of any change of use or urban redevelopment of existing mobilehome park developments. The MHPOD further relines and updates the procedural requirements for mobilehome park closure and resident relocation contained in Chapter 9.40, raises the required review and approval level for the relocation plan to the City Council and contains additional findings which must be met regarding the closure of the existing mobile home park. Thirty two existing mobile home parks were incorporated into the MHPOD, thereby subjecting them to the applicable objectives and policies established therein. More specifically, Policy LUT 34.A.2 states that at the time of any proposed change of use and/or rezoning of any of the 32 properties listed under the mobile home park overlay district, the City Council shall review the relocation plan, which shall contain provisions to mitigate any adverse impacts of the conversion of a mobile home park on the affected residents. The adopted policies relied heavily on compliance with Chapter 9.40 of the Municipal Code with its own established sets of procedures to follow. What is unique about this rezone request is that all residents have been relocated and the site is totally vacant. Jade Bay Mobile Home Park, filed bankruptcy in 2006. The Bankruptcy Court exercised its jurisdiction to effect park closure. Thereafter, the City retained special bankruptcy counsel to attend the bankruptcy proceedings and (to the extent possible) to help ensure that the residents' relocation needs were met. While the City was not involved with the bankruptcy proceedings, it did monitor the situation. 4-6 I I ! i. Meeting Date: 8/10/10 Page 7 During the bankruptcy proceedings, Jade Bay submitted a Bankruptcy Plan that proposed to provide the residents with relocation benefits of approximately 15% of the appraised value of their coaches. The tenants were then olTered full appraised value if residents signed legally binding stipulations approved by the Federal bankruptcy judge and vacated the premises earlier. (See Attachments 3 and 4). In the stipulations, each resident legally waived his or her rights to demand additional relocation benefits in the future. Since the conclusion of the bankruptcy proceedings, all of the residents of the Park moved out of the Park; thus, leaving the Park in its current vacant state. It is important to note that the "Applicant" for the rezone (who is the owner of the subject property), and Jade Bay, former operator of the Park are "legally" two separate entities. The applicant has prepared documentation that was submitted to the City, which describes why it contends that the bankruptcy proceedings superseded local ordinances regarding mobilehome park closures. Since the Park is currently vacant and since the former residents executed Federal Court approved stipulations formally accepting the relocation benefits offered to them by Jade Bay as satisfying their relocation claims, the relocation provisions of Chapter 9.40 are not applicable in this particular instance (i.e., notification procedures etc). Specific areas where the applicant has complied with applicable areas of this Chapter are described below. The mobile home park no longer exists on the project site and there are no residents who will be displaced as a result of the requested rezone action. Nonetheless, as part of the Rezone application, the applicant has provided detailed supplemental information to the City as to why he believes the previous owner complied with Chapter 9.40 and the MHPOD in the context of the Federal Bankruptcy proceedings. This information has been incorporated into the findings detailed in the following section. Policy 34.A.2, referenced above, outlines findings that must be made in order to consider the rezoning of a property currently zoned MHP, as specifically stated below: LUT 34.A.,2 At the time of consideration of any change of use and/or rezoning of any of the mobilehome properties noted above, the City Council shall review the plan prepared under Policy 34.A.1 and prior to taking action on said change of use and/or rezoning in accordance with the requirements of Nlunicipal Code Chapter 19.U6 and section 19.12030, shall make the following findings, as outlined below: That the proposed change in use and/or rezoning will not adversely affect attainment of the City's goal to provide a variety of hal/sing options within the City. The proposed change in use/rezone will not adversely affect the City's housing goals since the project site is currently vacant and, therefore, does not currently contribute any units towards the housing stock. Since the development of the Jade Bay Mobile Lodge there has been a greater diversity of housing types developed for a variety of income limits within Chula Vista, offering 4-7 Meeting Date: 8/10/10 Page 8 more varied housing options. Rezoning of the property to allow for multi-family development will help achieve the City's goal of achieving a variety of housing types. This will help achieve the goal of General Plan Policy LUT 1.9, which is to provide opportunities for development of housing that respond to diverse community needs in terms of density, size, location and cost. Multi-family allows. for either rental or condominium units to be developed on the site. Typically, the rents or sales prices for these units would be lower than that of a single-family dwelling. The City's General Plan land use designation for this site is currently RH so that the rezoning would result in the existing zoning to be brought into greater conformance with the General Plan. Further, this would help achieve the City's General Plan policy of achieving a variety of housing options. Policy LUT 1.19 requires that land use intensities be evaluated in conjunction with any zone change and/or General Plan Amendment to permit density or modify intensity. Factors to be considered include, but are not limited to, the maximum intensity allowed for the applicable land use designation in the General Plan, traffic circulation patterns, environmental constraints, and compatibility with surrounding land uses. The requested rezone to R-3 is the most consistent zone with the existing RH designation of the General Plan. The proposed change of use and/or rezoning is supported by sound planning principles, and higher density, affordable replacement housing within the City will remain in sufficient supply. The General Plan designation for the project site is RH that allows for multi-family development at a density range of 18-27 dwelling units per acre, a higher density than is typical for a mobilehome park type development. Thus, the proposed change to R-3 zoning is consistent with the City's desire for higher density development in the area. Any future development will be required to comply with the City's Balanced Communities Clnclusionary") Housing Element Policy tor affordable housing. As stated in General Plan Policy H5.1, newly constructed residential development projects containing 50 or more'"units, shall include a minimum of 10% as affordable housing. Since the proposed zoning will allow for multi-family housing consistent with the high density designation of the General Plan, it will provide for more affordable housing units than other types of residential development. Future development of the site will provide housing opportunities to many in the form of affordable rental or ownership units due to the inclusionary policy mentioned above. That the proposed change of use and/or rezoning will not result in severe or undue hardship on affected mobilehome resident. There will be no undue hardship on "affected mobilehome residents" as there are currently no mobilehome home park residents to be "affected" by the rezone. All of the residents agreed to vacate the park, signed contracts agreeing to accept the relocation benefits under the confirmed Chapter II plan as full settlement of any and all claims they had or may have in the future for relocation benetits, and subsequently moved out of the mobile home park over three years ago. Additionally, the applicant has indicated that the previous tenant, Jade Bay, provided assistance above and beyond that required by the court. As the site is currently vacant, no residents will be 4-8 Meeting Date: 8/10/10 Page 9 atIected by, nor suffer "severe or undue hardship" from the rezone; thus, this condition has been met. That the property owner and/or project proponent plan complies with applicable City and State mobile home park conversion and relocation regulations. The State mobile home park regulations addressing closure and rezone are expressly inapplicable in situations where the park operator is adjudicated bankrupt. Though such regulations are not applicable, the Federal Bankruptcy Court did ensure that the tenants received relocation benefits and that the park was closed in accordance with City of Chula Vista regulations to the extent possible. The tenants also agreed to sign a contract accepting the benefits as complete satisfaction of any claims they might have under state or local law. All residents did so. Most importantly, the requirement of a plan is only applicable in situations where there is an existing mobilehome park with residents. The site is currently vacant and no residents live on the site; therefore, this finding that the property owner and/or project proponent complies with applicable city and state mobile home park regulations has been met. That prior to the commencement of any closure of the mobilehome development. that the property owner(s) will prepare and ensure conformance of a detailed closure and relocation plan consistent with the requirements of CVl14~C Section 9.40 and applicable State regulations, and to the satisfaction of Directos of Development Services.. The specific requirement to prepare and ensure conformance of a detailed closure and relocation plan "prior to the commencement of any closure' is not applicable under the existing circumstances as the property owners are not requesting the closure of the Jade Bay Mobile Lodge. The park was closed previously through the federal bankruptcy proceedings. In addition, there are no residents currently residing in the park; thus, there are no individuals to relocate or to which benefits would be due'through this action. This finding is, therefore, inapplicable. As implied by the discussions above, the intent of state law related to mobilehome parks is to protect existing residents from the adverse affects that may occur due to the closure or rezone of a mobilehome park. The relocation plan is a mechanism by which the legislature can ensure that needs of existing residents are considered and the potential impacts of a closure are evaluated. It follows that where there are no existing residents to be affected by a rezoning and no relocation benefits to be provided, a relocation plan would not further the intent of the legislature - to protect existing residents. In the current situation, the site is empty. There are no existing residents, nor have there been for over three years; thus, no existing resident would be affected by a rezone, nor would relocation benefits be due, as there is no one to relocate. Additionally, state law expressly provides that such obligations (i.e. drafting a plan, providing relocation benefits, etc.) that might otherwise apply to a mobilehome park operator seeking to close or rezone do not apply following an adjudication of bankruptcy. As the site is currently empty, there are no residents, and the operator was adjudicated bankrupt, all of the requirements of state and local law intended to protect existing residents have been met to the extent that they were applicable. All of the prerequisites to rezoning have, therefore, been met. 4-9 Meeting Date: 8/10/10 Page 10 Voluntary City Actions Relatcd to Tenant Relocation After 40 years of operation, the Jade Bay Mobile Lodge filed Chapter II bankmptcy and noticed residents of the intended park closure on April 26, 2006. At that time, of the seventy-five spaces in the park, fifty-seven were occupied by residents who owned their coaches. As previously discussed, under normal circumstances these residents would have been eligible for relocation assistance as required by State laws governing the closure procedure for mobilehome and trailer parks. Since the related provIsIons of state law are expressly inapplicable in situations where an operator is adjudicated bankrupt, staff was directed through referrals at a May 4, 2006 Council Mobilehome Workshop to investigate the City's options regarding the Jade Bay Mobile Lodge bankruptcy and its effect on residents. Based on this referral, Special Bankmptcy Counsel was hired to monitor the bankruptcy proceedings and on several occasions, staff, counsel, and various City Council members met with the residents to explain the bankmptcy process to them, at an expense of$67,618. After the bankruptcy proceedings were settled in late 2006, all 40 remaining residents were provided with the following information on affordable housing options and available atIordable housing assistance: (1) The City retained a relocation specialist to provide staff with assistance in determining the residents' eligibility for City assistance and/or other programs at a cost to the City of $12,000. (2) Affordable rental opportunities throughout the City - Staff worked with several affordable complexes to hold vacancies for a two to three month period to provide priority to displaced Jade Bay residents. In addition, residents were provided information and priority to apply for Seniors on Broadway, under construction at that time. Fourteen residents were relocated to affordable housing units, leaving a surplus of affordable units available because some people turned down units based on individual preferences (nine additional residents were eligible). (3) First-time home buyer programs for low and moderate-income residents through the City's inclusionO/:v housing policy - Residents eligible for first-time home buyer opportunities at Mar Brisa, in San Miguel Ranch were encouraged to apply. While four households were potentially eligible, no households successfully applied. (4) Section 8 rental assistance - All eligible residents were encouraged and/or assisted in applying for Section 8 assistance through the County of San Diego. Prior to closure three households were already receiving Section 8 assistance and to date one additional household has qualified for the program. (5) HOlvfE Investment Partnership (HOldE) Program funds to assist very low and low- income residents with rent and security deposits - Council approved a Tenant Based Rental Assistance (IBRA) Program on January 23, 2007. While over half of the remaining residents were eligible for this Program, sixteen Jade Bay households accepted assistance. Today, eight households remain assisted with approximately 6 months left in the program and $250.706 expended as of June 30, 2010. 4-10 Meeting Date: 8/10/10 Page 11 In all, four residents chose not to participate in the eligibility process, four were determined to be over the income limits that would qualify them to receive any type of affordable assistance and nine others chose other housing options due to personal preferences, while twenty three (58%) received some type of affordable assistance. Compliance with Chapter 19.80 ofChu/a Vista Municipal Code The provisions of Chapter 19.80 (which are based upon the Cummings Initiative) are not applicable to this rezone request, since MHP is not one of the specific zoning categories listed in 19.80.070. It should also be noted that per Section 4.92 of the Land Use and Transportation Element of the City's General Plan, mobilehome parks are listed under the category of the "Medium-High Residential" density category (11-18 dwelling units/acre) which is the same density category as the R-2 zoning designation. The next highest category of "High Residential" density category (18-27 dwelling units/acre) is most consistent with the R-3 zoning category, which is only one residential zoning category higher than the R-2. Thus, even if the Cummings Initiative were to apply to this site (which it does not) the rezone request would be consistent with this provision since MHP is only one zoning category higher than Medium Density Residential (R-2). DECISION-MAKER CONFLICTS: Staff has reviewed the property holdings of the City Council and has found no property holdings within 500 feet of the boundaries of the property, which is subject to this action. CURRENT FISCAL YEAR IMPACT: The applicant has paid all costs associated with processing of the proposed rezone. ~. ,I, ONGOING FISCAL IMPACT: There will not be anyon-going fiscal impacts associated with the rezone because the site IS vacant and no project is proposed at this time. Attachments 1. Locator Map 2. Planning Commission Resolution 3. Figures 4. Letter to Tenant dated 12/12/06 5. Stipulation by and between Debtor and Park Tenant 6. Chapter 9.40 Chula Vista Municipal Code 7. Section 7. 17 of Land Use and Transportation Element ofChula Vista General Plan 8. Meeting Minutes from Planning Commission 9. Ownership Disclosure Form j :\p [ann ing\casctiles\09 (FY08-09\PCZ\pub 1 ichearing\pczOg-04 4-11 ATTACHMENT 1 LOCATOR MAP 4-12 I . I ! . . . . . . . . . . . . . . . . . . :tJ . . . . . . . . . . , , \- ,a~jECT " \ UDCliUiti! , . . , . . , . . . , , . . . . . . . ..-- . , .<5' '-D '. -;;:J ~% ';.-iZ. ..~ , . . . . , . . . . , . . . . , . . . . . . . . . , , , . . . . j) 'Cl '" o 0> (1) is c o m Vacant C HULA VISTA PLANNING AND BUILDING DEPARTMENT LOCATOR PROJECT SKK Realty, LLC. C) APPLICANT: PROJECT 701 0 Street ATTACHMENT 1 ADDRESS: SCALE: FILE NUMBER: NORTH No Scale PCZ-08-04 . , ., 7 ATTACHMENT 2 PLANNING COMMISSION RESOLUTION , ~ 4'-14 u~_ RESOLUTION NO. PCZ-OS-04 RESOLUTION OF THE CITY OF CHULA VISTA PLANNING COMMISSION RECOW,IENDING TRA T THE CITY COUNCIL ADOPT REZONE PCZ-08-04 FOR 4.35 ACRES LOCATED AT 701 D STREET. WHEREAS, a duly verified application for a Rezone was filed with the City ofChula Vista Planning Department on June 9, 2008, by SKK Realty, LLC ("Applicant"); and WHEREAS, the Applicant requests approval of an amendment to the adopted zoning map or maps established by Section 19.18.010 of the Chula Vista Municipal Code in order to rezone the Project Site from the MHP (Exclusive Mobilehome Park) Zone to R-3 (Multi Family Residential, Precise Plan) Zone with a "P" Precise Plan Modifying District ("Project"); and WHEREAS, the area ofland commonly known as 701 D Street, which is the subject matter of this Resolution, and is depicted in Exhibit "A", attached hereto and incorporated herein by this reference, and which coru;ists of one parcel totaling 4.35-acres located at 701 D Street ("Project Site"); and WHEREAS, the Environmental Review Coordinator has reviewed the proposed proj ect for compliance with the California Environmental Quality Act (CEQA) and determined that since the proposed rezone was adequately covered in previously adopted General Plan Update Final Environmental Impact Report, EIR 05-01 no further environmental review or documentation in necessary; and WHEREAS, the Development Services Director set the time and place for a hearing on the Project and notice of said hearing together with its purpose was given by its publication in a newspaper of general circulation in the city and its mailing to property owners within 500 feet of the exterior boundaries of the property, at least 10 days prior to the hearing; and WHEREAS, the hearing was held at the time and place as advertised, namely 6:00 p.m., June 24,2009, in the Council Chambers, 276 Fourth Avenue, before the Planning Commission and said hearing was thereafter closed; and 'iVHEREAS, the Planning Commission having received certain evidence on June 24, 2009, as set forth in the record of its proceedings and hereby incorporated herein byreference as though set forth in full, made certain findings, and recommended that the City Council approve the Project, based on certain terms and conditions. NOW, THEREFORE, BE IT RESOLVED THAT THE PLANNlNG C01vIMISSION recommends that the City Council adopt the attached Draft City Council Ordinance adopting Rezone PCZ -08-04, rezoning the Project Site from the MHP (Exclusive Mobilehome Park) Zone to the R--3-P (Multi Family Residential, Precise Plan) Zone with "P" Modifying District and Draft City Council Resolution for Findings for rezoning a site related to the Mobilehome Park Overlay District. 4-15 Planning Commission Resolution - PCZ 08-14 Page 2 PASSED Ai"ID APPROVED BY THE PLANNING COMMISSION OF lliE CITY OF CHULA VISTA, CALIFORNIA, this 24th day of June, 2009, by the following vote, to-wit: AYES: NOES: ABSENT: ABSTiliN: ATTEST: Spethman, Moctezuma, Clayton, Vinson Thompson Tripp, Felber Diana Vargas, Secretary Presented by: Gary Halbert, P .E., AICP Deputy City ManagerlDevelopment Services Director 4-16 William C. Tripp, Chair Approved as to form by: Bart Miesfeld City Attorney ATTACHMENT 3 FIGURES 4-17 .j:> 1- ~ , CD ~Vt- ~~ ~- O"~ (HUlA Vl'ifA 701 0 Street; Existing Zone "MHP" A NORTH <'" b; o z ::: 0... (1) a: .. .. Q) C 0 N -0 Q) CIl 0 Q. 'C 0 Ql ~ cnColc., 0... OC~ CoeCi:: eN . .. .. +-J e- Q) Q) ~ +-J (/) 0 r- 0 T"- '":;;,;Ul. . 4-19. ~~l\\~~. ~ltl5~ o ATTACHMENT 4 LETTER TO TENANT DATED 12/12/06 4::"-2b. ,() -- --r&-----J' , iJ-/ /f/o 6 COMMUNITY DEVELOPMt:N DEPARTMENT I l DEe 1 J'~006 J December 17_ 2006 - -..-." COMMUNI, Y D':.:'JEL~- - O c'., uP~J!' ~n'" ~PA.RTM:::N: !.IC1\J l ~~'~' DEe 1 5 2005 Dear Tenant: -- Attached are two original agr=ents. Pleas" follow the directions below to expedite the payment process: 1. Pi"""" read the agreement arn:i sign both ropies.. Keep one fur your files 2. .AfiEr you fuI1,-e signed the agreement return one original agn:ement to MamJ",<>er, B:uhara Barnes with a signed copy ofy-our titk to your molnlclJ.ome. 1be sign.."'li ropy of your title MUST be atbcl1erl. 3. We will =ndngreement with the copy of title to the Court fur llppIOval 4. Yon should be =ei:ving your payment wi:!lrin 10 tD 12 days from date of filing agr=nent wiJh the Court. Sin=ly, ~-- Kennefu Kubota 4-21 OFFER TO PURCHASE CLAIM To: From: Space No. The Kubota Family As you may be aware, the Bankruptcy Court recently approved Jade Bay's Chapter 11 Plan, which provides that the mobile home park will close on April 26, 2007. As part of the Plan, you may be allowed a "Mobilehome Value Claim" if you intend to abandon your mobilehome in the park upon vacating. Pursuant to testimony during the plan confirmation hearing, estimates were given that tenants would receive approximately 15% of their Mobilehome Value claim based 'upon the claim being allowed in the amount of the appraisal commissioned by Jade Bay. . Your mabi/ehome was appraised as having an insurance replacement value of: Based upon the estimate of a 15% distribution, the amount you would receive under the Plan would be: We are prepared to offer you the full amount of the appraised value of your mobilehome. This offer would require you to agree to vacate the park no later than February 28,2007 and sign over title to your mobilehome. It would also require that you sign the following documents: 1. Stipulation for Possession, effective March 1, 2007; 2. stipulation that Allowed Claim equals the Appraisal; 3. Assignment of Certificate of Title; 4. Release and Waiver of Claims; 5. Assignment of Claim. See the next page for the details of this offer. 4-22 Page 2 *What you will receive under this offer* If you accept this offer, you will receive $7,264 ($7,764 less $500 holdback to be paid upon vacating the park), less the amount of rent and estimated utilities you would be required to pay through February 28,2007, upon signing of all documents. You would thereafter be allowed to stay in the park without paying any additional rent until February 28,2007. The holdback of $500 would be paid to you when you turn in your keys and vacate the park on or before February 28, 2007. If you vacate prior to February 28, 2007 you would also receive a refund of unearned rent and utilities. . If you do not vacate the park in a timely fashion, you will not be entitled to the balance of $500 holdback and may be subject to court proceedings, additional rent and penalties for failing to timely vacate the park. Compare: Compare this offer to the amount you are likely to receive under the Bankruptcy Pia n: Under the Plan. we estimate you would receive: Under this Offer, you would receive: s described above.' This offer is open for a limited time only. This Offer will rernain open until December 19, 2006. If you are interested in pursuing this offer or have any questions, please contact Irene Ikeda at 714/545- 6332. You will then be fOJ"Narded a package of documents for your review and consideration. . Relocation Assistance Is Now Available The Kubota Family has retained Mecky Meyers to provide relocation advice and assistance to all tenants. Ms. Meyers will be available to assist you in your effort to locate replacement housing, regardless of whether you accept this offer. Ms. Meyers can be contacted at 213/820-1639. We look forward to hearing from you. Thank you, The Kubota Family 4-23 ATTACHMENT 5 STIPULATION BY AND BETWEEN DEBTOR AND PARK TENA.N:T ,. - ,F,,,",, 4'::24 I , -. , o UJ CJ o 9 ,)~,: '" ..... (l) -0 I' ,. IC: "'0 - .- c-,"'c :~~ Co:J:.:j E~~ 1-, ':~: ,- . .<001 .._0>- ../-01 ::0: ~ U) 0-;:: b.(J -. c: :;::- ~ v Todd C. Ringstad (State Bar No. 973 Nanette D. Sanders (State Bar No. 120169 RINGSTAD & SANDERS LLP ?030 Main Street, 12th Floor line, CA 92614 Iephone: 949.851.7450 ~ 4 ~~;; csimile: 949.851.6926 I 2 3 5 N U Lu = 7 8 9 10 11 12 13 14 15 16 11 ]8 ]9 20 2] 22 23 24 25 26 27 .~. eneral Insolvency Counsel for pter 11 Debtor and Debtor-in-Possession, ay Mobile Lodge, Inc. RECEIVED ORIGIN L DEe L 9 2006 I I 1 , , ! '.-..~ _.------- .-.----. rf~ r~.D i-b;;;~i -<001.. ~272W6 CLERK u.5.. B.A.\IU1UPTCY COUlfJ' CENTilAl~lCTOfClllFrnltU. flY Dol>ur'IOott'I; ENTERED llC. ~g d 'IE 2'8 an; UNITED STATES BANKRUPTCY 0 Cl.if.l'.lU 1l"\'"J"c'I~. C"'J;rl roU/!.;L~:;IiI)Q iJl- t~jlwi.r( CENTRAL DISTRICT OF CALlFORNIA - SANTA A1'1~ "7';' In re JADE BAY MOBILE LODGE, INC., a California Corporation, Debtor and Debtor-in-Possession. ~;:, CASE No. SA 06-10581 ES Chapter 11 Proceeding STIPULATION BY AND BETWFRN n1?,RTOR4ND PARK TENANT, REGARDING: (I) i\.jV.l.."n~MENT AND ALLOWANCE OF TENANT MOBILEHOME VALUE CLAIM; (2) ASSIGNMENT OF MOBILEHOME VALUE CLAIM TO KENNETH KUBOTA; (3) TRANSFER OF MOBILEHOME TO DEBTOR, ASSIGNMENT AND INDEMNIFICATION REGARDING TITLE; (4) EARLY TERJ'VIINATION OF RENTAL AGREEMENT, REMOVAL OF TENANT AND ALL OTHER OCCUPANTS AND IMMEDIATE ISSUANCE OF WRIT OF POSSESSION; AND, (5) RELEASE OF CLAIMS; ORDER THEREON [No Hearing RequiredJ. TO THE HONORABLE ERITHE A. SMITH, UNITED STATES BANKRUPTCY JUDGE, AND ALL PARTIES IN INTEREST: 28 111 439802..2 / / 4-25 ;. \ 2 3 4 5 6 7 8 9 10 11 '" 12 '""' Ql -0 \ ' 13 C ~~ t~ -'Jj"";-;:: 14 .-!:=.1 .j I ';;1 IS CIJ ~. ~ ::r:~ rn' 0":;- 0.01 8~ 16 .:: .. i:'2 17 18 19 20 21 22 23 24 25 26 27 28 ,-,. J This stipulation ("Stipulation") is entered into by and between Jade Bay Mobile Lodge, Inc., a California corporation ("Jade Bay" or "Debtor"), the debtor and debtor-in-possession herein, Kenneth Kubota as Claim Assignee, and ("Tenant"), a tenant of the Jade Bay Mobile Lodge (the "Park") pursuant to the terms of a month-to-month rental agreement. This Stipulation is based on the following facts and circumstances: , A. The Debtor is in the business of operating the Park, which is located at 701 "D" Street in Chula Vista, California. Prior to the commencement of this Chapter 11 case, in the ordinary course of its business, the Park entered into a month-to-month rental agreement with Tenant for the rental of Space No. lt the Park. Tenant owns the mobilehome located at Space No. B. The Debtor commenced this bankruptcy proceeding by the filing of a voluntary Chapter II petition on April 26, 2006 in the United States Bankruptcy Court for the Central District of California (the "Court"). On the petition date, the Debtor served all tenants of the Park with a notice that the Park would be closed within one year onhe notice, to wit, by April 26, 2007. C. The Court has confirmed the Debtor's chapter II plan, which provides a mechanism by which tenants of the Park can abandon their mobilehomes to the Debtor in exchange for a claim against the estate, and thereafter vacate the Park premises. D. A claims bar date of August 18,2006 was established by the Court. Tenant filed a "mobilehome value claim" prior to the claims bar date in the amount of $30,546.00. Subsequent to the claims bar date, Golden State Appraisals ("Golden State') performed a valuation of Tenant's mobilehome. Golden State determined that the value of Tenant's mobilehome, based upon "stanc\,ard insurance replacement criteria", as prescribed by Section 9.40.030 of the Chula Vista Municipal Code, is $4,476.00 (the "Mobilehome Value Claim"). E. Subsequent to plan confirmation, the shareholders ofthe Debtor extended an offer to Tenant whereby they offered to pay Tenant the full value of Tenant's Mobilehome Value Claim, as determined by the appraiser, less certain specified sums as detailed hereinbelow. Tenant has accepted the offer from the shareholders and this stipulation is intended to 4398022 4.:.26 .. ] 2 3 4 5 6 7 8 9 10 11 '" 12 '"' Cl.) "d I ' 13 r'! ,,- ., ;;;::; ." .."'0 , --:~~ 14 ~<:":;;E"": ..J ~ o- J.::::.... .:J I ~3: 15 ro -;;.~ ....... :=;: ~ CJ:I c:;:: Oll -. 16 ~ g- ~ 17 ]8 19 20 2] 22 23 24 25 26 27 28 '-' v memorialize the terms and conditions thereof, Now, therefore, the parties hereto do hereby agree and stipulate as follows: 1. Tenant's Mobi]ehome Value Claim is hereby amended and allowed in the amount of$4,476.00. The Claims Docket shall be amended to reflect the amendment and allowance of Claim No. 28 in the amount of$4,476.00. 2. Tenant hereby assigns all interest in Claim No. 28 and all other claims or rights Tenant may have in this Chapter]] case to Kenneth Kubota (the "C]aim Assignee"). 3. Tenant shall assign title to Tenant's mobilehome to the Debtor. effective as ofthe date of Court approval ofthis Stipulation. In connection therewith, Tenant has executed all necessary documents to transfer legal title of the mobilehome to the Debtor, including the Certificate of Title as issued by the State of California, Department of Housing and Community Development, a true and correct copy of which is attached hereto as Exhibit"]" and incorporated by this reference. 4. Tenant warrants that there are no valid liens or'encumbrances against the mobilehome and that title to the mobi]ehome is transferred to the Debtor free and clear of all liens and encumbrances. Tenant agrees to indemnifY, defend and hold harmless any claims made against the Debtor by any person or entity regarding hislher transfer of title to the Debtor as provided herein, regarding any claim or interest asserted by any person or entity as to the mobilehome, ownership interests. right to occupy or liens asserted for security. 5. Tenant agrees to vacate himselflherself, all other occupants or guests of the premises, and to remove any and all persona] property from the Park on or before February 28. 2007. Tenant agrees to leave the premises in broom clean condition and shall maintain all existing insurance coverage on the mobilehome until the date he/she vacates the Park premises. 6. A writ of possession shall issue upon the approval of this Stipulation by the Court, with a lock out date to occur no earlier than March 1, 2007. 7. The rental agreement by and between the Debtor and Tenant, a ,true and correct copy of which is attached hereto as Exhibit "2" and incorporated by this reference, shall be deemed rejected pursuant to ] 1 US.C. Section 365, effective as of the date of Court approval of 439802.2 4--tr . 1 2 3 4 5 6 7 8 9 10 11 '" 12 ..... 0) ~I- 13 ~ ~~ , ~ r. Mo.e . -:.~~ 14 '~j ]~~ d <::uc: 15 c:l .- ~ . '0 ..j...J ::i ~ '" ;:"E b.O ~- 16 ~ ~ 17 18 19 20 21 22 23 24 25 26 27 28 "--' ---.) this Stipulation. 8. Except for those claims and rights assigned to the Claim Assignee, and effective upon Tenant's receipt of the Settlement Funds as defined in Paragraph 10 below, Tenant, hislher respective successors and assigns and each of them, and hislher respective officers, directors, employees, agents, representatives, shareholders, affiliates, successors and assigns, hereby fully and completely release, remise and waive any all claims, actions, causes of action: liabilities, obligations and other demands, including any relating to the Mobile Home Value Claim as set forth above, whether know or unknown, suspected or unsuspected, that'Tenant may possess against Jade Bay Mobile Lodge, Inc., its officers, directors, employees, agents (including but not limited to Star Mobilehome Park Management, Inc., Michael Cirillo, Barbara Barnes and Betty McCauley), representatives, shareholders, affiliates (including but not limited to the Sadakichi Sam Kubota Statutory Trust), successors or assigns, on account of, based upon or in any way related to any of the facts and circumstances giving rise to the Mobilehome Value Claim, or any other claims arising out of orrelated to the operation of the Jade Bay Mobile Lodge, the Debtor's Chapter 11 proceeding, the rejection of the rental agreement described above, or the real property located at 701 "D" Street in the City of Chula Vista, San Diego County, California. 9. Waiver of California Civil Code Section 1542. The Parties hereby expressly waive and relinquish any and all rights and benefits they may otherwise have under or by reason of Section 1542 of the California Civil Code (which provides as set forth below) and/or any other statutes or common law principles of simila~ effect. "A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executirig the release, which if known by him must have materially affected his settlement with the debtor." 10., In exchange for the above consideration from Tenant, including the releases specified in Paragraph 8 and 9 above, the Claim Assignee has agreed to pay to Tenant the sum of $3,141.96, representing Tenant's Mobilehome Value Claim in the amount of$4,476.00, less estimated rent <<hd utilities in the amount of$834.04 ($342.02 rent, $75.00 utilities, for two . months _ January and February 2007) for Tenant's continued occupancy at the Park from the date hereof through February 28, 2007, less a holdback (the "Holdback") in the amount of $500.00 (in 439S02.2 4":'~8 . 2 3 4 5 6 7 8 9 10 II tJJ 12 ..... Cll -0 0 13 ~ i c::~ ;..,;;' -:.!! 14 '~jJ~ d I ~J IS 4-J ;.; C tI) c";: OJ:! ~. 16 ~ ~- iYl 17 18 19 20 21 22 23 24 25 26 27 28 '-' v total the "Settlement Funds''). The Settlement Funds will be paid to' tenant within five business days following Court approval of this Stipulation. The Claim Assignee will pay over to the Debtor the estimated rent and utilities withheld from the Settlement Funds and the Holdback. The Debtor will pay the Holdback to Tenant on February 28, 2007 provided Tenant permanently vacates the Park and surrenders hislher keys to the Park manager on that date. If Tenant vacates the Park prior to February 28, 2007, the Debtor will refund to Tenant any unearned rent and utilities. If Tenant does not vacate the Park on or before February 28,2007, Tenant will not be entitled to receipt of the Holdback and may be subject to additional rent and penalties for failing to timely vacate the Park, and to further court proceedings, either before the Bankruptcy Court, as provided by the Debtor's confmned plan, or before the State courts, as deemed appropriate under the circumstances in the Debtor's discretion. II. Failure to comply ",ith any term of this Stipulation will be deemed a breach hereof and shall result in Tenant's forfeiture of the Holdback as defined in paragraph 10 above. 12. This Agreement is the final and entire agreement among the Parties concerning the subject matter of this Agreement. All agreements of the Parties with respect to the subject matter hereof are in writing and supersede all prior written and oral agreements and understandings of the Parties. This Agreement cannot be modified except by a written document signed by the Parties affected by the modification. None of the Parties is relying upon any other negotiations, discussions, representations, warranties (except any warranties by representatives of parties regarding authority to enter into this agreem~nt), promises or agreements in connection with the subject matter of this Agreement. No supplements or modifications or waivers or terminations of this Agreement shall be binding unless executed in writing by the all of the Parties. This is a fully integrated agreement. 13. All of the terms and provisions of this Agreement shall be binding upon or shall inure to the benefit of the Parties, their assigns, heirs, trustees, administrators, executors, estates or successors. 14. This Agreement may be executed in any number of counterparts each of which shall be deemed an original, but all of which taken together shall constitute one agreement. An 439302.1 4 =-29 > 2 3 4 5 6 7 8 9 10 11 '" 12 H OJ "d \- 13 ~ i~ 1..~ ."< 14 ,~ ::.E j-',;;;; 15 cd -EO ....... ~ i '" ~.~ CJl 16 >:: " ;:2 17 18 19 20 21 22 23 24 25 26 27 28 '-" J electronic signature or a copy of an original signature transmitted by facsimile shall be as valid as the original signature. 15. The Parties do hereby acknowledge and agree that they have heen represented by, or have had the opportunity to seek representation by, independent counsel of their own choice throughout all negotiations which preceded the execution of this Agreement. 16. It is understood and acknowledged that none of the Parties or their agents, has made any promise, representation, or warranty whatsoever, express or implied, except as expressly set forth herein, to induce the other to execute this Agreement. The Parties acknowledge and agree that they have not executed this Agreement in reliance upon any such promises, representation or warranty not expressly set forth in this Agreement. 17. It is understood and acknowledged that each of the Parties hereto enters this Agreement of his own free will, and no threats, coercion, or duress have been employed to induce any of the Parties hereto to execute this Agreement. 18. The Parties stipulate that the United States Bankruptcy Court for the Central District of California shall continue to have jurisdiction to enforce or declare rights under this Agreement. If for any reason the Uoited States Bankruptcy Court lacks jurisdiction or declines to exercise jurisdiction then the rights under this Agreement may be declared or enforced by another court of competent jurisdiction located in the State of California. 19. The Parties hereby agree to execute such other documents and to take such other action as may be reasonably necessary to further the purpose of this Agreement with the Parties to bear their own respective costs and attomeys= fees for these additional actions. 20. Any person executing this Agreement on behalf of any party does hereby personally represent and warrant to the other Parties that he or she has the authority to execute this Agreement on behalf of, and to fully bind, such party. 21. The Parties represent and warrant that they have not sold, assigned or transferred, or purported to sell, assign or transfer, and shall not hereafter sell, assign.or transfer, any obligations, liabilities, demands, claims, costs, expenses, debts, controversies, damages, rights, ..tJ9&J2.2 4':'~O I , , I ..~ 2 3 4 5 6 7 8 9 10 11 ~ 12 ~ OJ '""Cl 0' 13 c:: .- '" ""';:0 U"J - .- 14 ~&:1iE;; oJ :.2;; J-:.:.. U l~u~ 15 ~ ..... .w 'i. ~ ~I~~ 16 c:: M Pi; 17 18 19 20 21 22 23 24 25 26 27 28 v v actions, or causes of action released pur.mant to this Agreement. The Parties .also agree to defend, indemnify and hold one another harmless against any obligation, liability, demand, claim, cost, expense (incl1Uling but not Iirruted to attorneys' fees incurred), debt, controversy, damage, action or Cause of action based on, arising out of or in connection with any such sale, transfer or assignment or purported sale, transf", or assignment. DATED: December 1$ 2006 DATED: Dec~ber ~ 2006 . ~-1j~~ Kenneth Kubota, ClaunAssignee DATED: December 20 , 2006 RlNGSTAD&'~ BY.~ . ~/~ General Insolvency Cou:osel for Debt;a1?.i Debtor- in-Pos~ssion, JADE BAY MOBILE LODGE, INC.. ORDER The Stipulation is granted in its entirety. f~(/A.u TIlE HONORABLE .ERITHE A. SMITH IT IS SO ORDERED. DATED: tlEtZ7m PRESENTED BY: RINGSTAD & SANDERS LLP By. ~~ General Insolven~ Counsel ~,~ ll11d Debtor-in-Possession, JADE BAY MOBlLE LODGE, INC. <39!02.2 - 7 - 4-31 1 2 3 4 5 6 7 8 9 10 11 12 I ~ 13 o~ ~~ ~~ N C - .~ 14 :j ].~: .....l ~'-U'\ cLI;:;;~ ..su~ 15 ... _0\ ;E, o- J - , 0- 16 N 17 18 19 20 21 22 23 24 25 26 27 28 Todd C. Ringstad (State Bar No. 97345) Nanette D. Sanders (State Bar No. 120169) RlliGSTAD & SANDERS LLP 2030 Main Street, 12th Floor Irvine, CA 92614 Telephone: 949.851.7450 Facsimile: 949.851.6926 General Insolvencv Counsel for Chapter 11 Debto; and Debtor -in-Possession, Jade Bay Mobile Lodge, Inc. UNITED STATES BAt"lliRUPTCY COURT CEl'<lRAL DISTRICT OF CALIFORNIA - SANTA ANA DIVISION Inre JADEBAYMOBILELODGE,INC., a California Corporation, Debtor and Debtor -in-Possession. CASE No. SA06-10581ES Chapter 11 Proceeding STIPULATION BY AND BETWEEN DEBTOR AND PARK TENANT, BARBARA N1JNl\<.U,F,E, REGARDING: (1) AMENDMENT AND ALLOWA..l'{CE OF TENANT MOBILEHOME VALUE (:LAIl\'I; . (2) ASSIG~IENT OF MOBILEHOME VALUE CLAIM TO KENNETH KUBOTA; (3) TRANSFER OF MOBILEHOME TO DEBTOR,AS~G~IENTAND INDEMIDFICATION REGARDING TITLE; (4) EARLY TERMINATION OF RENTAL AGREEMENT, REMOVAL OF TENANT At'ID ALL OlllER ocm ANTS AND ThTh'IEDIATE ISSUANCE OF WRIT OF POSSESSION; AND, (5) RELEASE OF CLAIMS; ORDER THEREON [No Hearillg Required] TO THE HONORABLE ERITHE A. SlVIITH, UNITED STATES BANKRUPTCY JUDGE, AND ALL PARTIES IN INTEREST: III 4-32 1 2 3 4 5 6 7 8 9 10 11 12 I" 13 I g~ ~- _ N N"'O -:.:~ 14 .::.; u E""= f.....l"".... ~.....l ~~~ I ..::I:..l~ 15 , . .~ , "'~ I 0- 0 ~, 0- 16 , N , I , 17 18 19 20 21 22 23 24 25 26 27 28 This stipulation ("Stipulation") is entered into by and be<.'ween Jade Bay Mobile Lodge, hiC., a California corporation ("Jade Bay" or "Debtor"), the debtor 8..'ld debtor-in-possession herein, Kenneth Kubota as Claim Assignee, and Barbara Nunnelee ("Tenant"), a tenant of the Jade Bay Mobile Lodge (the "Park") pursuant to the terms of a month-to-morrth rental agreement. This Stipulation is based on the following facts and circU1TIstances: A. The Debtor is in the business of operating the Park, which is located at 701 '1)" Street in Chula Vista, California. Prior to the commencement of this Chapter 11 case, in the ordinary course of its business, the Park entered into a month-to-month rental agreement with Tenant for the rental of Space No. B-19 at the Park. Tena.'lt owns t.~e mobilehome located at Space No. B-19. B. The Debtor commenced this bankruptcy proceeding by the filing of a voluntary Chapter 11 petition on April 26, 2006 in the United States Bankruptcy Court for the Central District of California (the "Court"). On the petition date, the Debtor served all tenants of the Park with a notice that the Park would be closed within one year of the notice, to wit, by April 26, 2007. C. The Court has confirmed the Debtor's chapter 11 plan, which provides a mechanism by which tenants of the Park can abandon their mobi1ehomes to the Debtor in exchange for a claim against the estate, and thereafter vacate the Park premises. D. A claims bar da.te of August 18, 2006 was established by the Court Tenant filed a. "mobilehome value claim" prior to the claims bar date in the amount of$40,000.00. Subsequent to the claims bar date, Golden State Appraisals ("Golden State") performed a valuation of Tenant's m9bilehome. Golden State determined that the value ofT errant's mobilehome, baSed upon "standard insurance replacement criteria", as prescribed by Section 9.40.030 of the Chula Vista Municipal Code, is $7,764.00 (the "Mobilehome Value Claim"). E. Subsequent to plan confirmation, the shareholders of the Debtor extended an offer to Tenant whereby they offered to pay Tenant the full value of Tenant's Mobilehome Value Claim., as determined by the appraiser, less certain specified sums as detailed hereinbelow. Temut has accepted the offer from the shareholders a"d this stipulation is intended to 4-33 1 2 " J 4 5 6 7 8 9 10 11 12 I' 13 2::!;' ~'o _ N "N""o ....~:; 14 ,0.;";:::'":' fj ~~~ I <n-;;;~ I .::o~ 15 i ~.;a. , .<, I ~""E b ;l- 16 I I I I 17 18 19 20 21 22 23 24 25 26 27 28 memorialize the terms and conditions thereof Now, therefore, the parties hereto do hereby agree and stipulate as follows: 1. Tenant's Mobilehome Value Claim is hereby amended and allowed in the amount of $7,764,00, The Claims Docket shall be amended to reflect tt'1e amendment and allowance of Claim No. 46 in the amount of $7, 764.00. 2. T _ h~,by ~."" ill 1m~," in C1' ;~ No. 46 "'" ill o"'~ d,1m' 0':"" J Tenant may have in this Chapter 11 case to Kenneth Kubota (the "Dillm Assignee"). 3. Tenant shall assign title to Tenant's mobilehome to the Debtor, effective as ofL'1e date of Court approval of this Stipulation. In comlection therewith, Tenallt has executed all necessary documents to transfer legal title ofi:.t'1e mobilehome to t.1}e Debtor, including the Certificate of Title as issued by the State of California, Department of Housing and COIDi-numty Development, a tJ.-ue and correct copy ofwhich is attached hereto as Exhibit "1" and incorporated by this reference. 4. Tenant warrants that there are no valid liens or encumbrances against the mobilehome and that title to the mobilehome is transferred to the Debtor free and clear of all liens and encumbrances. Tenant agrees to indemnify, defend and hold harlnless any claims made against the Debtor by any person or entity regardillg hislher transfer of title to the Debtor as provided herein, regardi,-'lg any claim or interest asserted by any person or entity as to the mobilehome, ownership interests, right to occupy or liens asserted for security. 5. Tenant agrees to vacate himsel:fJherself, all other occupants or guests of the premises, and to remove any and all personal property from L'1e Park on or before FebrufuJ' 28, 2007. Tenant agrees to leave the premises in broom clean condition and shall maintain all existing insurance coverage on the mobilehome lli,til the date he/she vacates the Park premises. 6. A writ of possession shall issue upon the approval of this Stipulation by the Court, 'lNiili a lock out date to occur no earlier than Mardl 1,2007. 7. The rental agreement by 3.,TJd between the Debtor and Tenant, a true and correct copy of which is attached hereto as Exhibit "2" and incorporated by this reference, shall be deemed rejected pursuant to 11 U.S.C. Section 365, effective as of the date ofCou.Tt approval of 4-34 1 2 3 4 5 6 7 8 9 10 11 12 'I ~~ 13 , ~~ I - ~ ;:"""0 1 '":-.':!~ 14 1""",8.": ij ~~~ .-" i -=cJ~ 15 . '0 , ;!~ , g"'E b ~- 16 , , , , I 17 18 19 20 21 22 23 24 25 26 27 28 this Stipulation. 8. Except for ,,':lose claims and rights assigned to the Claim Assignee, and effective upon Tenant's receipt of the Settlement Funds as defined in Paragraph 10 below, Tenant, hislher respective successors and assigns and each of them, and hislher respective officers, directors, employees, agents, representatives, shareholders, affiliates, successors and assigns, hereby fully and completely release, remise and waive any all claims, actions, causes of action, liabilities, obligations and other demands, including any relating to the Mobile Home Value Claim as set forth above, whether know or unknown, suspected or tL11SUspect~, that Tenant may possess against Jade Bay Mobile Lodge, Inc., its officers, directors, employees, agents (including but not limited to Star Mobilehome Park Management, Inc., Michael Cirillo, Barbara Ba.-nes and Betty McCauley), representatives, shareholders, affiliates (including but not limited to the Sada.1dchi ram Kubota Statutory Tru:9, successors or assigns, on account of; based upon or in any way related to any of the facts and circumstances giving rise to the Mobilehome Value Claim, or any other claims arising out of or elated to the operation of the Jade Bay Mobile Lodg , the Debtor's Chapter 11 proceeding, the rejection of the rental agreement described above, 0 the real property located at 701 '1)" Street in the City ofChula Vi San Diego County, California. 9. Waiver of California Civil Cod~ction 1547.IThe Parties hereby expressly waive and relinquish any and all rights and benefits they may otherwise have under or by reason of Section 1542 of the California Civil Code (which provides as set fort..h below) and/or any other statutes or co=on law principles of similar effect. "A general release does not extend to d~iJT1s which the creditor does not know or suspect to exist in his favor at the time of . a . e, which if known by him must have ma en y mect bis settlement withthe debtor." 10. In exchange for the above consideration from Tenant, including the releases specified in Paragraph 8 a.'1d 9 Move, the Claim Assignee bas agreed to pay to Tenant the sum of $6,379.96, representing Tenant's Mobilehome Value Claim in the amount of$7,764.00, less estimated rent and utilities in the amount of $884.04. ($342.02 rent, $100.00 utilities, for two months :- January and February 2007), for 1j:~~t' s continued occupancy at the Park from the date hereof,,'uowll Februarv 28.2007. less a holdhack (the "Holdback", in the amouilt of 1 2 3 4 5 6 7 8 9 10 11 c;) 12 ;...; Q) d , 13 8 ~: -': ~ ~ 0 -.~ 14 ~ ....-<:~ ........... . ....J..c,... --i....J ~=:~ u -=u~ 15 ~ ..-"" .f-J ;:q VJ ;;t CO ~- 16 ~ :2 17 18 19 20 21 22 23 24 25 26 27 28 $500.00 (m total the "Settlement Funds"). The Set'"Jement Funds 'Will be paid to tenant within five business days following Court approval of this Stipulation. The Claim Assignee will pay over to the Debtor the estimated rent and utilities witlli'leld from the Settlement Funds and the Holdbae-x:. The Debtor will pay the Holdback to Tenant on February 28,2007 provided Tenant permanently vacates the Park and surrenders hislher keys to the Park manager on that date. If Terumt vacates the Park prior to February 28,2007, the Debtor will refund to Tenant any unearned rent-and utilities. If Tenant does not vacate t.he Park on or before February 28,2007, Tenant wiJl not be entitled to receipt of the Holdback and may be subject to additional rent and penalties for failing to timely vacate the Park, and to further court proceedings, either before the Ba..T1kruptcy COlli-t, as provided by the Debtor's commed plan, or before the State courts, as deemed appropriate under the circumstances in the Debtor's discretion. 11. Failure to comply with any term of this Stipulation will be deemed a breach hereof and shall result in Tenant's forfeiture of the Holdback as defined in paragraph 10 above. 12. This Agreement is the final and entire agreement among the Parties concerning the subject matter ofL'lls Agreement. All agreements of the Parties with respect to the subject matter hereof are in writing and supersede all prior written and oral agreements and understandings of the Parties. This Agreement cannot be modified except by a written document signed by the . Parties affected by the modification. None of the Parties is relying upon any other negotiations, discUssions, representations, warranties (except any w3...'Tanties by representatives of parties regarding authority to enter into this agreement), promises or agreements in connection with the subject matter of this Agreement. No supplements or modifications or waivers or terminations of this Agreement shall be binding unless executed in writing by the all of the Parties. This is a fully integrated agreement. 13. All of the terms arid provisions of this Agreement shall be binding upon or shall inure to the benefit of the Pa..-ties, the',r assigns, heirs, trustees, admi'-llstrators, executors, estates. or successors. 14. This Agreement may be executed in any number of counterpa..-ts each of which shall be deemed an original, but all ofwbich taken together shall constitu1:e one agreement. An 4-36 ~ 1 2 3 4 5 6 7 8 9 10 11 12 15 ::JI' 13 ::: I "'~ _ . N .U ~ Q> Q ~..~ 14 ~...; iE~ -lu:>.... "-~ j.....JI'/O.::;~ 15 :0 ~o_~ ...J. :<~ " ~e >iJ ~- 16 - - a 17 18 ]9 20 21 22 23 24 25 26 27 electronic signature or a copy of an original signature tra."lsmitted by facsimile shall be as valid as the original signature. ]5. The Parties do hereby acknowledge and agree that they have been represented by, or have had the opportunity to seek representation by, independent counsel of their own choice throughout all negotiations which preceded the execution of this Agreement. ] 6. It is understood and acknowledged that none of the Parties or their agents, has made any promise, representation, or warranty whatsoever, express or implied, except as expressly set forL'l herein, to induce the other to execute this Agreement. The Parties acknowledge and agree that they have not executed this Agreement in reliance upon any such promises, representation or warranty not expressly set forth in this Agreement. 17. It is understood and acknowledged that each of the Parties hereto enters this Agreement of his own free 'Will, and no threats, Cv"efcion, or duress have been employed to induce any ofllie Parties hereto to execute this Agreement. 18. The Parties stipulate that the United States Bankruptcy Court for the Central District of California shall continue to have jurisdiction to enforce or declare rights under 11us Agreement. If for any reason the United States Bankruptcy Court lacks ju.-isdiction or declines to exercise jurisdiction then the rights under this Agreement may be declared or enforced by another court of competent jurisdiction located in the State of California. 19_ The Parties hereby agree to execute such ot,'ler documents and to take such o<..her action as may be reasonably necessary to further the pmpose of this Agreement with the Parties to bear their own respec'"..ive costs and attorneys= fees for these additional actions. 20. Any person executing tr1.is Agreement on behalf of any pal1y does hereby personally represent a..'ld warrant to the other Pa.'ties tr'lat he or she has the auL'lority to execute this Agreement on behalf of; and to fully bind, such party. 21. The Parties represent fu""ld warra11t that they have not sold, assigned or transferred, --. or purported to sell, assign or transfer, and shall not hereafter sell, assign or transfer, lll1Y oblio-ations liabilities demands claims ct~ 7expenses debts controversies, dalnages, rights, 1;;1) } ~ " ,) .. 1 2 3 4 5 6 7 8 9 10 11 n 12 '" 1.) ::l , 13 ~ ~:;: ~ ~ ;.,,~o .v 0 - .~ 14 .-~ <:l"' · eo: -J"c"'" :j -J Gi~~ 15 :'0 ~u_:; ....J ;:2 ~ n :;,:1: :ll) ~- 16 ~ ~ ~ 17 18 19 20 21 22 23 24 25 26 I actions, or causes of action released pursuant to this Agreement. The P3.l"1:ies also agree to defend, indemni.."y and hold one a.'lother harmless against any obligation, liability, demand, claim, cost, expense (including but not limited to attorneys' fees incurred), debt, controversy, damage, action or cause of action based on, arising out of or in connection with any such sale, transfer or assier.ment or purported sale, transfer or assignment. "DATED: December{5,2006 ~ ~ Barbara Nu,melee [Tenant] DATED: December --' 2006 Kenneth Kubota, ClaimAssignee DATED: December -----' 2006 RlNGSTAD & SANDERS LLP By: Nanette D. Sanders General Insolvency Counsel for Debtor and Debtor -in-Possession, JADE BAY MOBJLE LODGE, mc. ORDER The Stipulation is granted in its entirety. IT JS SO ORDERED. DATED: "IRE HONORABLE ERITHE A SMITH PRESENTED BY: RINGSTAD & SANDERS LLP By: Nanette D. Sanders 4- 3 8 General Insolvency Counsel for Debtor STATE OF CALlFORNIA-JJ.E,l?A[!NiENT OF HOUSiNG AND COMiviUNiTY CERTIFICATE UF-TITLE MOBILEHOME DEVELOPiviENT DECAL NO AAC17 0 - ,'AANUFACTURE.'\ NAME/ID TRADE I\lAME MaDEL DaM DOT DFS 5PC EX?\RAT1O, GREAT LAKES/ GREAT LAKES 00/00/00 00/00/b4 ABQ 08/3L193 R'{-f,.:t u SEiHAL NUMBER LAEEL/INSiGNIA NUMBER WEiGHT l"'rH Wlorn ISilJ~ I 5'f ~EMPT r8SE ~' 1 G4G5510FD~~S4934 000000 000 bO 000105 03/ 7 93 3 Sr 1 J TOTAL 4 FEES 5 PAID: 6 $3.00 A NUNNELEE BARBARA A o 701 D ST SP Bl9 D CHULA VISTA CA 92010-1223 R ~. RELEASE OF DEALER ** NEW REG~5TERED OWNER, FILL =N ~TEHS ~ - 9 ** s 4.A) AND OR Bl 5 5 E NAME - pLEASE PRINT ,..ti,,;,,~ t,~.'..:_".~.;~.'~.r.~. ~~.~.,.m ..:>;... ";,.,-",,~, .. - . 't~~~""'\'cC'"'C .(~:*''" CHULA VISTA .~'':\CIi' 92010-1223 ~ --;,Pu,J~ <lcJ1~~:(~ i RELEt\5E... '6F REGISTERED oWNER _4! -';.:~~" 701 D ST SP B19.,i' ..;, CHULA VISTA i~:.i:'fi HUH HE LEE ~^p~?A A ;f"l Jr;~ ';'-;' .-' .. ~"r ,.." l7J},:;T MAILING ADD?ESS '. ; M r A ; I r L 701 D ST SP 819 Bl ST ZIP . . Crr! (.,.:: p CNTY FUTURE kAILLNG ADDRESS ~~~~:~ o il7$f?f~;j~~ .~':NEW'LE "'. .: ,~_\.:-..~_'-}~t:;..:.;} C~:,;.'t>:;.. ST ZIP LOCATIOH;,rA~~~~;:;S ~t:~'.-Y o S I T E U R S I'~. -.:-~:~) ,~/ " ,-- " . ~~~-l PRICE OAT'::: Q W N E R ~~1~; ~~~;~ Ii j! ~".~",. :r::':;~ L 6J~~__ '.....,::...:.~.~>..c,.~.:....:.;...~ I ' - ~>-- ; ~kJ?r~ RELEASE m: LEGAL CiWNER fl:~'~"~~ RETENTION .60F _,.pEGAL OWNER ~~'ff' 4ir '_d" .J).!!./i.>[."t?J ASSIGNMENT OF;~<IdE.GAt. aViNER 4 ./~' ll-.?<!.~; _ ~~', r...,,~ ~ ji. ~~~M jl~"'"'~ .~ ~~r !~f j 1 1j4o " ~ ~ :~ I! j I ER, OWNER:'::S.;~.NATURE FILL IN IT:EHS.:1:0 - 12 *** s G A L .ff_l! , \ttf~:Y:~ NAME - P~~;~~7wrr AD.DRESS~ 'i~\~.) 2.Al n. >2. CITY ..4-'" ~~~C:NTY JR. ~t'Hj9t::.DER':' FILL ~"'-"V ~~ ~r?~ .'r>' NAks. - PLEASE ST IN ITEMS l.3 ZIP 15 *** *** NEW J..ST C, PRINT J U F N I I R Q S R T ADDRESS em c:NTV ST ZIP ~ NEW 2ND ~R. ~ENHOLDER, FILL IN ITEMS l6 - 13 *** 15. L I E N 5 16. MAME - ?LEASE PRZHT E 17. ADDRESS C L 0 o N E 0 R lB. cMTY ST ZIP 01-071-0r CITY IMPORTIJtlT<l.9 THIS CERTIFICATE OF TITLE MAY HOT. REfLECT AL~ LIENS RECORDED nF HOUSING AND COMMUNITY DEVELOFMENT AGAINST THE DESCRIBED ..._. __ ~~,...-.,..."""L<t::"" Tuonlrr.:::J-.i T~F WITH THE DEPARTMENT UNIT. THE CURRENT DEPARTMENT. 01000ao \....../ Todd C. Ringstad (State Bar No. 973 Nanette D. Sanders (State Bar No. ] 20 16 RINGSTAD & SANDERS LLP 030 Main Street, 12'h Floor ] ine, CA 92614 Iephone: 949.851.7450 csimile: 949.851.6926 eneral Insolvency Counsel for pter 11 Debtor and Debtor-in-Possession, ay Mobile Lodge, Inc. - RECEIVED 0 Ole, "100r, t... .,. Tic.(, _ RI.[- , ,. I i-b-~'c.-~/;}<;cG ! \ ~27~; ClERi::u:;..eA.'lffiUPTCYCOV1l'T 1 aHTIUJ.. Dlsnucr OF CAUFOfltV. \ BY c.ou.-,c~'f' :lL ENTERrn'-"'-c, r:.~, Q.C ..Sr:~") , flEe: 2i8 d.'UJ i i UNITED STATES BANKRUPTCY OU '",,,",~~i J CENTRAL DrSTRlCT OF CALIFORNIA- SANTA ANf"~"'."'~~";';.i,::~ In re JADE BAY MOBILE LODGE, INC., a California Corporation,- Debtor and Debtor - in-Possessi on. CASE No. SA 06-1 0581 ES Chapter 11 Proceeding STIPULATION BY AND BETWEEi DEBTOR AND ,PARK TENANT, Sl),"liKO FARROW, REGARDING: (1) AMENDMENT A."iD ALLOWANCE OF TENANT MOBILEHOME VALUE CLAIM; (2) ASSIGNMENT OF MOBILEHOi\E VALUE CLAIM TO KENNETH KUBC'TA; (3) TRANSFER OF MOBILEHOME TO DEBTOR, ASSIGNMENT AND INDEMNIFICATION REGARDING TITLE; (4) EARLY TER.J'rIINA TION OF RENTAL AGREEMENT, REMOVAL OFTEN",iiT AND ALL OTHER OCCUPANTS Af'i1: IMMEDIATE ISSUANCE OF WRIT OF POSSESSION; AND, (5) RELEASE OF CLAIMS; ORDER THEREON . [No Hearing Required] TO THE HONORABLE ERITHE A. SMITH, UNITED STATES BANKRUPTCY JUDGE, AND ALL PARTIES IN INTEREST: III 431)8D2.1 / /' 4-40 > 2 0 J 4 5 6 7 8 9 10 II n 12 " u ~I 13 " 14 "-' " 31 15 n' :.01 16 2 17 18 ]9 20 21 22 23 24 25 26 27 28 "---' oJ This stipulation ("Stipulation") is entered into by and between Jade Bay Mobile Lodge, Inc., a California corporation ("Jade Bay" or "Debtor"), the debtor arid debtor-in-possession herein, Kenneth Kubota as Claim Assignee, and Sumiko Farrow ("Tenant"), a tenant of [he Jade Bay Mobile Lodge (the "Park") pursuant to the terms of a month-to-month rental agreement. This Stipulation is based on the fol1owing facts and circumstances: A. The Debtor is in the business of operating the Park, which is located at 701 "D" Street in Chula Vista, California. Prior to the commencement of this Chapter II case, in the ordinary course of its business, the Park entered into a month-to-month rental agreement with Tenant for the rental of Space No. A-I at the Park. Tenant OVll1S the mobilehorne located at Space No. A-I. B. The Debtor commenced this bankruptcy proceeding by the filing of a voluntary Chapter II petition on April 26, 2006 in the United States Bankruptcy Court for the Central District of California (the "Court"). On the petition date, the Debtor served all tenants of the Park with a notice that the Park would be closed within one year of the notice, to wit, by April 26, 2007. C. The Court has confirmed the Debtor's chapter II plan, which provides a mechanism by which tenants of the Park can abandon their mobilehomes to the Debtor in exchange for a claim against the estate, and thereafter vacate the Park premises. D. A claims bar date of August 18, 2006 was established by the Court, Tenant filed a "mobilehome value claim" prior to the claim,S bar date in the amount of $30,546.00. Subsequent to the claims bar date, Golden State Appraisals ("Golden State") performed a valuation of Tenant's mobilehome. Golden State determined that the value of Tenant's mobilehome, based upon "standard insurance replacement criteria", as prescribed by Section 9.40.030 of the Chula Vista Municipal Code, is $4,476.00 (the "Mobilehome Value Claim"). E. Subsequent to plan confirmation, the shareholders of the Debtor extended an offer to Tenant whereby they offered to pay Tenant the full value of Ten ant's Mobilehome Value Claim, as determined by the appraiser, less certain specified sums as detailed hereinbelow. Tenant has accepted the offer from the shareholders and this stipulatIon is intended to .1}9SD22 - 2 - 4-41 , 2 3 4 5 6 7 8 9 10 1\ 12 IJ 13 " c..;; 14 " J ~ )1 ~ 15 16 " 17 18 19 20 21 22 23 24 25 26 27 28 \....-- o memorialize the terms and conditions thereof. Now, therefore, the parties hereto do hereby agree and stipulate as follows: 1, Tenant's Mobilehome Value Claim is hereby amended and allowed in the <un.,'",,', of$4,476,00, The Claims Docket shall be amended to reflect the amendment and allowance 'J' Claim No, 28 in the amount of$4,476,OO, 2, Tenant hereby assigns all interest in Claim No, 28 and all other claIms or rig], . Tenant may have in this Chapter 11 case to Kenneth Kubota (the "Claim Assignee"), 3, Tenant shall assign title to Tenant's mobilehome to the Debtor, effective as c'the date of Court approval of this Stipulation, In connection therewith, Tenant has executed all necessary documents to transfer legal title of the mobilehome to the, Debtor, including the Certificate of Title as issued by the State of California, Department 0 f Housing and Community Development, a true and correct copy of which is attached hereto as Exhibit" 1" and incorporated by this reference, 4, Tenant warrants that there are no valid liens or encumbrances against the ' mobilehome and that title to the mobilehome is transferred to the Debtor free and clear of all liens . and encumbrances, Tenant agrees to indemnify, defend and hold harmless any claims made against the Debtor by any person or entity regarding hislher transfer of title to the Debtor as provided herein, regarding any claim or interest asserted by any person or entity as to the mobilehome, ownership interests, right to occupy or liens asserted for security, 5, Tenant agrees to vacate hirnsi:lf/herself, all other occupants or guests of the premises, and to remove any and all personal property from the Park on or before February 28, 2007, Tenant agrees to leave the premises in broom clean condition and shall maintain all existing insurance coverage on the mobilehome until the date helshe vacates the Park premises, 6, 'A writ of possession shall issue upon the approval of this Stipulation by the Coun, with a lock out date to occur no earlier than March 1,2007, 7, The rental agreement by and between the Debtor and Tenant, a true and correct copy ofwnich is anached hereto as Exhibit "2" and incorporated by this reference, shall be deemed rejected pursuant to 11 U,S,c. Section 365, effective as of the date of Court approval of 4398022 ,3, 4-42 . 2 3 4 5 6 7 8 9 10 11 ) 12 , ) T 13 . , , " " ~ . 14 I.... ~ ~ ' r 15 , " ) 0 ~ ~ 16 , J , 17 18 19 20 21 22 23 24 25 26 27 28 ~ J this Stipulation, 8. Except for those claims and rights assigned to the Claim Assignee, :'fl:' upon Tenant's receipt of the Settlement Funds as defined in Paragraph 10 below, Ie,:,., .c'".; respective successors and assigns and each of them, and hislher respective officers, dir,:c:u,:, employees, agenLs, represematives, shareholders, affiliates, successors and assigns, here~::' L,;" and completely release, remise and waive any all claims, actions, causes of action: h obligations and other demands, including any relating to the Mobile Home Value Ci,. forth above, whether know or unknown, suspected or unsuspected, that Tenant mr,! ~0::: .c. against Jade Bay Mobile Lodge, Inc., its officers, directors, employees, agents (includii'>; ':.'!\ not . limited to Star Mobilehome Park Management, Inc., Michael Cirillo, Barbara Barnes OJ,,,, L ,.try McCauley), representatives, shareholders, affiliates (including but ITot limited to the Sad ..kd,i Sam Kubota Statutory Trust), successors or assigns, on account of, based upon or in an,' ,':C',' related to any of the facts and circumstances giving rise to the Mobilehome Value Clei:,'. D: eny other claims arising out of or related to the operation ofthe Jade Bay Mobile Lodge, th.. l'ebtor's Chapter 11 proceeding, the rejection of the rental agreement described above, or the reol property located at 701 "D" Street in the City ofChula Vista, San Diego County, California, 9. Waiver of California Civil Code Section 1542, The Parties hereby expressly waive and relinquish any and all rights and benefits they may otherwise have under or c.:- reason of Section 1542 of the California Civil Code (which provides as set forth below) and/o! :L~Y other statutes or common law principles of similar effect. "A general release does not extend to claims which the creditor does nol know cr suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor." I O. In exchange for the above consideration from Tenant, including the reie~ses specified in Paragraph 8 and 9 above, the Claim Assignee has agreed to pay to Tenant Lee sum of $3,141,96, representing Tenant's Mobilehome Value Claim in the amount of $4,476.00, less estimated rent and utilities in the amount of $834.04 (S342.02 rent, 575.00 utilities, for two months - January :L'1d February 2007) for Tenant's continued occupancy at the Park from the date hereof through February 28, 2007,Ie55 a holdback (the "Holdback") in the amount of 5500.00 (in llJ9S02.2 .4. 4-43 2 3 4 5 6 7 8 9 10 II 12 J 13 - 14 -.~ [' IS c , ~ 16 17 18 19 20 21 22 23 24 25 26 27 28 o v i I total the "Settlement Funds"). The Settlement Funds will be paid to tenant within five busmc:" days following Court approval of this Stipulation. The Claim ASSlgnee will pay over Ie, ll,' Debtor the estimated rent and utilities withheld from the Settlement Funds and the Hold:.':..'. The Debtor will pay the Holdback to Tenant on February 28, 2007 provided Tenant permar.""'!'/ vacates the Park and surrenders hislher keys to the Park manager on that date. IfTenar.t vcCHes the Park prior to February 28, 2007, the Debtor will refund to Tenant any unearned rent 2-n.'. utilities. If Tenant does not vacate the Park on or before February 28,2007, Tenant will; . ',,<2 entitled to receipt of the Holdback and may be subject to additional reni and penalties for f,. nng to timely vacate the Park, and to further court proceedings, either before the Bankruptcy CC,'''1, as provided by the Debtor's confirmed plan, or before the State courts, as deemed appropria:, u;der the circumstances in the Debtor's discretion. 11. Failure to comply \11th any term of this Stipulation wll1 be deemed a bredc'; hereof and shall result in Tenant's forfeiture of the Holdback as defined in paragraph 10 above 12. This Agreement is the final and entire agreement among the parties conce,,,ing the . subject matter of this Agreement. All agreements of the Parties with respect to the subject matter hereof are in writing and supersede all prier written ar,d oral agreements and understandings of the Parties. This Agreement cannot be modified except by a written document signed by the Parties affected by the modification. None of the Parties is relying upon any other negotiations, discussions, representations, warranties (except any warranties by representatives of parties regarding authority to enter into this agreement), promises or agreements in connection with the subject matter of this Agreement. No supplements or modifications or waivers or terminations of this Agreement shall be binding unless executed in writing by the all of the Parties. This is a fully integrated agreement. 13. All of the terms and provisions of this Agreement shall be binding upon or shall inure to the benefit of the Panies, their assigns, heirs, trustees, administrators, executors, eslates or successors. 14. This Agreement may be executed in any number of counterparts each of which shall be deemed an original, but all of which taken together shall constitute one agreement. An .:139802.1 .5- 4-44 2 3 4 5 6 7 8 9 10 11 , 12 , , 110 13 , 0 ! LJ: .. 14 .J. ~ -';; r 15 , - ) c ~ ~, 16 I 17 18 19 20 21 22 23 24 25 26 27 28 ~ J electronic signature or a copy of an original signature transmitted by facsimile shall be as valid as the original signature. IS. The Parties do hereby acknowledge and agree that they have been represented by, or have had the opportunity to seek representation by, independent counsel of their own choice throughout all negotiations which preceded the execution of this Agreement. \6. It is understood and acknowledged that none of the Parties or their agents, has made any promise, representation, or warranty whatsoever, express or implied, except as expressly set forth herein, to induce the other to execute this Agreement. The Parties acknowledge and agree that they have not executed this Agreement in reliance upon any such promises, representation or warranty not expressly set forth in this Agreement. 17. It is understood and acknowledged that each of the Parties hereto enters this Agreement of his own free will, and no threats, coercion, or duress have been employed to induce any of the Parties hereto to execute this Agreement. 18. The Parties stipulate that the United States Bankruptcy Court for the Central District of California shall continue to have jurisdiction to enforce or declare rights under this Agreement. If for any reason the United States Bankruptcy Court lacks jurisdiction or declines to exercise jurisdiction then the rights under this Agreement may be declared or enforced by another court of competent jurisdiction located in the State of California. 19. The Parties hereby agree to execute such other documents and to ta.'<e s1.!ch other action as may be reasonably necessary to further the purpose ofthis Agreement with the Parties to bear their own respective costs and attorneys= fees for these additional actions. 20. Any person executing this Agreement on behalf of any party does hereby personally represent and warrant to the other Parties that he or she has the authority to execute '. this Agreement on behalf of, and to fully bind, such party. 2 l. The Parties represent and warrant that they have not sold, assigned or transferred, or purported to sell, assign or transfer, and shall not hereafter sell, assign or transfer, any obligations, liabilities, demands, claims, costs, expenses, debts, controversies, damages, rights, 4J9RD2.2 - 6- 4-45 . 2 3 4 5 6 7 8 9 10 II ~ 12 ~ ~I' 13 c " '"' . VJ ~ 14 3d oJ" .J~ ~Ii. 15 ~ 0 DJl - 16 c:; ~ i2 17 18 19 20 2] 22 23 24 25 26 27 28 \...../ v actions, or causes of action released pursuant to this Agreement. The PariiesaIso agr22 t,) indemniJY and hold one another harmless against any obligation, liability, demand, c:'. . expense (including but not Hn-,ited to attcmeys' fees incw-red), debt, controversy, 00':<. Or Cause or action based on, msing out or or in connection with any such sale, transfer (.c assignment or purported sale, transfer or assignment. DATED: Dec=ber 1$ 2006 A-u~,,;:t<, .:ft,,~~ 1/)(>) Sumiko Farrow [Tenant] DATED: Dece,nbcrW,2006 ~--j,/, ~d-k Kenneth Kubota, Cl8.1mAssignee DATED: December 20 , 2006 LLP /' By. ~~' . /7 T _.A _ {;V.._y .. . ~~","~ General Insolvency COllIJsel for Debtor ili~ci i)cotor- in-Poss<ossion, JADE BAY MOBILE LODe::, INC. " ORDER The Stipulation is granted in its entirety. f~t7~ TIlE HONORA.BLE ERITIIE A. SMITE IT IS SO ORDERED. DATED: m 27m PRESENTED BY: RlNGST AD & SANDERS LLP E"~~p General Insolvency Counsel for ebtoi<7"" ~ and Debtor-in-Possession, JADE BAY MOBILE LODGE, INC. m802,) - 7 - 4-46 OFFER TO PURCHASE CLAIM To From: Sumiko Farrow, Space No, A-1 The Kubota Family ,t.,s yOIJ may be aware, the Bankruptcy Court recently approved Jade Bay's Chapter 11 Plan, which provides that the mobile home park will close on ,0.,p,t: :)6, 2007 As part of the Plan, you may be allowed a "Mobilehome Value Claim" if you Intend to abandon your mobile home in the park upon vacating, Pursuant to tesllmony dl1ring the plan confirmation hearing, estimates were given that tenants would receive approximately 15% of their Mobilehome Value claim based Ur_)n - the Claim being allowed in the amount of the appraisal commissioned by Jade Bay y'our mobilehome was appraisad as having an insurance replacement value of. $4,476, o Based upon the estimate of a 15% distribution, the amount you would receive under Ihe Plan would be, S4,476x15%= $671.40 We are prepared to offer you the full amount of the appraised value oj your mobllehome, This offer would require you to agree to vacate the park no lat~r Illan February 28,2007 and sign over title to your mobilehome, It would alse require Ihat you sign the following documents: 1 Stipulation for Possession, effective March 1,2007; 2 Stipulation that Allowed Claim equals the Appraisal; 3 Assignment of Certificate of Title; 4 Release and Waiver of Claims; 5 Assignment of Claim, See the nexl page for the delails 01 this offer, 4-47 v Todd C. Ringstad (State Bar No. 973 Q) Nanette D. Sanders (State Bar No. 120169) RlNGST AD & SANDERS LLP 030 Main Street, 12'h Floor 1 ine, CA 92614 IeDhone: 949.851.7450 E" csimile: 949.851.6926 eneral Insolvency Counsel for Dter II Debtor and Debtor-in.Possession, : ay Mobile Lodge, Inc. RECEIVED 0 DEe 2s 200~J_...__n_R~ rH f~n I' ,i;. ..:./ I ,-.--...-.... I i bc:.c.; 7 .:l 00(., \ l ,,~~,~,:"~~ ' 1 aNTRAl D!311I.~ Of CJJ...IfoP.l4A I !'l' o..i: ENTERED ~ ..8 .; , : OO:2~~4 I UNITED STATES BANKRUPTCY OU 0.,,",~;J I CENTRAL DISTRICT OF CALIFORNIA - SAl"lT A ANf"''''''":~';;;;,'':;~ In re JADE BAY MOBILE LODGE, INC., a California Corporation,' Debtor and Debtor- in-Possession. CASE No. SA 06-1 0581 ES Chapter 11 Proceeding STIPULATION BY AND BETWEEN DEBTOR AND PARK TENANT, SUMIKO FARROW, REGARDING: (I) AMENDMENT AND ALLOWANCE OF TENANT MOBILEHOME VALUE CLAIM; (2) ASSIGNMENT OF MOBILEHOME VALUE CLAIM TO KENNETH KUBOTA; (3) TRANSFER OF MOBILEHOME TO DEBTOR, ASSIGNMENT AND INDEMNIFICATION REGARDING TITLE; (4) EARLY TERMINATION OF RENTAL AGREEMENT, REMOVAL OF TENANT AND ALL OTHER OCCUPANTS AND L'\fMEDIATE ISSUANCE OF WRIT OF POSSESSION; AND, (5) RELEASE OF CLAIMS; ORDER THEREON [No Hearing Required] TO THE HONORABLE ERlTHE A. SMITH, UNITED STATES BANKRUPTCY JUDGE, AND ALL PARTIES IN INTEREST: III 4J1)302.1 4-48 .\ I .-~\ L . / / thIS StIpulation. 8. Except for those C "=,,,AJ./Tg SHIPl-lEliTNO. SHIPUENTOATE :=;:';;;.::~:== 3 14 4 69 7 8 312 "'<::G:~:; . , ~ C::cli ',- e upon Tenant's receipt of the Sett FRO~ ICO"PANYHAJJEj . hIs/her forth above, whether know or un c;~' 'lars, respective successors and assign! employees, agents, representativ, "~')y fully and completely release, remise a: .b: lities1 obligations and other demands, i . ,'~ as set ".',~sess PHONE ( 1fl13J...!:!.2 5' - 7 2 2 q limited to Star Mobilehome Park Management, Inc., Michael Cirillo, Barbara Bai~i,,:.:n..d Beny against Jade Bay Mobile Lodge, I ~CCaUley), representatives, shareholders, affiliates (including DUt not limited to ti,e Sc'dakichi KENNETH KUBOTA ROBERT KUBOTA, ETG .. CLASS 4 ACCOUNT PH. 714-545--6332 17330 NEWHOPE ST. STE G FOUNTAIN VALLE'(, CA 92708 '.nY"V3Y 16-4935 122<l ro5\OO\3CA 2033 , ~n, or any DATE 1-3-07 Ile Debwr's o PAY TO THE DROE."? OF > 1$ 6,379.96 ;al property Six thousand three hundred seventy nine ando~&/~O~ :?~=' UNION BANK OF CALIFORNtA Ao)J,l,S AY1:1'I\,If #35 81399 AoJJ.U A'if.., HUHTlHGlOH Bu.Ol. CA 926.46 800238 "-i56 Space B-19 SIGNATURE BANKING ~~"" ---- -~ -.--"--'--- ressly by reason MEMO If any other ~._....''''''' Vl ,",VllllUVIl loW pnnclples or slmllar etfect. "A general release does not extend to claims which the creditor does not kno'.\' or suspect to exist in his favor at the time of executing the release, which ifknown by bim musl have materially affected his settlement with the debtor." 10. In exchange for the above consideration from Tenant, including the releases specified in Paragraph 8 and 9 above, the Claim Assignee has agreed to pay to Tenanlthe sum of 56,379.96, representing Tenant's Mobilehome Value Claim in the amount of $7,764.00, less estimated rent and utilities in the amount of$884.04 ($342,02 rent, $100,00 utilities, ['or 1\\0 months - January and February 2007), for Tenant's continued occupancy at the Pcrk fTom Ihe date hereof through February 28,2007, less a holdback (the "Holdback") in the amount of ,ngso::: 1 4-49" ~ ~ u ,~\ . )~ " t\ 2. ~J '-' 'fl,,-iGMi SHIPUEHT NO. SH1PUEI'-!T OAr;:: _~N~ _~/U~ 31Y"69 78216 this StIpulation. fROM {CO!.lPAHY NAM~ ~-I 8. 2 Except for those clai upon Tenant's receipt of the Settlen 3 4 respective successors and assigns ill 5 employees, agents, representatives,; 6 and completely release, remise and' 7 obligations and other demands, inch An" (NA","DEPT.) PHOHE set I UJIQ)'-/20-f,'-{D'I 8 forth above, whether know or up.kno'ml,Suspected or unsuspected, that Tenant may possess live s/her " 8 3, 'n ~. ~ u\\y ~. ~ " 9 against Jade Bay Mobile Lodge, Inc., its officers, directors, employees, agents (including but not Ie KENNETH KUBOTA ROBERT KUBOTA, ETG CLASS" ACCOUNT PH. 714-545-6332 17330 NE'NHOPE ST. STE G FOUNTAIN VALLEY, CA 92708 2023 16-~9 35 T220 ca5lC61304 11 DATE 1-3-07 1$ 3,302.96 12 13 PA \' TO THE ORDER OF_ ~::::~. Three thousand three hundred two and 96 100 A 14 - -DOlLARS lcJ UNION BANK OF CALIFORNIA SIGNATURE BANKING 15 16 \7 \8 19 20 21 22 23 24 25 26 I 27 ,0 \ _0 AD).Io.I.S Avt:I'lUi ,t'J5 a89'i ~ AYf.., HUtomHG10l'l au-CIi, CA 926-46 1300 2J5 ~-486 Space B-17 -~~-~----~! MEMO -J:\ty :hi y . any btor's " lper1)' waive ""'U rell11tjlmn any <U1U ~ll ng,m> allU uellOlllO LnOY OJay UUlorWloe n"vo unucr ur oy rcason of Section 1542 of the California Civil Code (which provides as set forth below) and/or any other statutes or common law principles of similar effect. "A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which iflc"lown by him must have materially affected his settlement with the debtor." 10. In exchange for the above consideration from Tenant, including the releases specifJedin Paragraph 8 and 9 above, the Claim Assignee has agreed to pay to Tenantlhe sum of $3,302.96, representing Tenant's Mobilehome Value Claim in the amount of $4,587.00, less estimated rent and utilities in the amount of$784.04 ($342.02 rent, $50 00 utilities, for [Wo months _ January and February 2007) for Tenant's continued occupancy at the Park from the dete \ hereof through February 28, 2007, less a holdback (the "Holdback") in the amount of S50000 Cn .;l:,9U)1.1 - 4 . 4-50 2 3 4 5 6 7 8 9 10 11 '" 12 '- v Di 13 ~ I . Cl " n -..'; 14 7)'" .J .0_ ,"- Jr; 15 Cl .. , , , ' ]6 ;:; ] 7 18 19 20 21 22 23 24 25 26 27 28 ~. ~ specified in Paragraphs 3 and 4 above, the Claim Asoignee shall pay to Tenant the sum of $8,463.00, representing Tenant's allowed Mobilehome Value Claim pursuant to the terms of this Stipulation, within five (5) days of Court approval of this Stipulation. DA TED: December ft. 2006 ' ,r '? /JyJ~ Cd;i ~ [Tenant] ~/UdJJ{ ijf:~ DA TED: December 1,O. 2006 _.A?.#'# ~~= SHIPLlEHT NO. SHIPl.lENT OATE 'WEIGhT ;laim] 314%9 78916 DATED: DecembeJ FAOM (COMPANY N)J,.lE) p ~ ~ ~~6~..r4 ~ 1sel for l7ebtor and @ ~ JDGE, We. ATTN; (!"^i.lEJD€PT.) The Stipulation is granted in its entirety. IT IS SO ORDERED. DATED: lID:! 1 /fO; ~;ui4C~ THEfrONORABLE ERlTHE A. SMITH KENNETH KUBOTA ROBERT KUBOTA, ETC CLASS 4 ACCOUNT PH. 714-545--6332 17330 NE'NHOPE. ST. STE G FOUNTAIN VALLEY. CA 92708 16-49 35 1220 0:J.51C613C4 2030 1-3-07 DATE PAY TO THE ORDER OF~ 1$ 8,463.00 Eiqh t thousand four hund rpn ~ i xt-y t-hrp", ~nd....+leqiOOs 61 ~,~.:::" UNION BANK OF CALIFORNIA ADMI.S AYH~Uf #J5 8899 AO,.l.MS A'ff.., HU/'ffi"'G,OH 8EACH. CA 926..6 800238.1"'86 Space C-ll MEMO SIGNATURE BANXING .../ rl / _..~ ~.____"". _._~~ ~-- 4J98D2.2 ,4, 4-51 ~ ~ thls Stipulation, "'!!!"'tJ.s..;r::T SHIP!.IEN'T HO. :;;HIPI.lEHT DATE -""'~-= 31Y %9 75114 '/'r1'::IGC"" 8, Except for those cia FROM (COMPANY NAM~ upon Tenant's receipt of the Settler respective successors and assigns a employees, agents, representatives, TO ICOM?mYNAMEj DHL CAr,NOT DEU\'~R TO P.O. BeA and completely release, remise and iA ZIP CODE {REeL'I;:E:: obligations and other demands, incJ fo rth above, whether know or unkn Ch I,~','e ,ihcr b, fully .! ~. :: s, c.. sel :q~S a2ainst Jade Bav Mobile Lodge. Inc" its officers, directors, employees, agents (inc!ud'cs but not I KENNETH KUBOTA ROBERT KUBOTA, ETC CLASS 4 ACCOUNT PH. 714-545-6332 17330 NEWHOPE ST. STE G FOUNTAIN VALLEY, CA 92708 15-49 ::l5 1220 0:J5100 I 304 2032 ~ 1":3~07 DATE c - PA Y TO THE ORDER OF 1$ 8,665.96 g Ii 10111GRs 6J "":,~.:: r Eiqht thousand ~ix hundred ( UNION BANK OF CALIFORNIA sixtv f;vp ';::!nn SIGNATURE BA..l'naNG ( Ao......u AYl!N"Uf ,JS 8699 )U)~ A'ft., HVN"m.clo,... StACH, CA 926-16 BOO 238 "-'ls6 Space C-17 -~-~--" MEMO ktly ichi ay ,r any :btor's . opCl1y l' waive and relinquish any and all rights and benefits they may otherwise have under or by re2son of Section 1542 of the Cali[ornia Civil Code (which provides as set forth below) and/or any olher statutes or common law principles o[ similar e[[ect. "A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time o[ executing the release, which i[known by him must have materially affected his settlement with the debtor," ! 0, In exchange for the above consideration from Tenant, including the releases specified.in Paragraph 8 and 9 above, the Claim Assignee has agreed to pay to Tenant the sum of S8,665,96, representing Tenant's Mobilehome Value Claim in the amount 0[$10,000,00, less estimated rent and utilities in the arnoW1t of$834,04 ($342,02 rent, $7500 utilities, for twO months - January and February 2007) [or Tenant's continued occupancy at the Park from the dJte I hereo[through February 28,2007, less a holdback (the "Holdback") in the amount ofS500 00 (in I 4 J 9S02.~ .4- 4-52 I 'T Ihis Stipulation. 2 8. Except for Ihose claims and rights assigned to doc Claim Assignee, and di, .:. II McCauley), rcprescnlatives. shareholders, affiliates (including but not limited t" th. ~'rl"kichi 10 limited 10 Stu Mobdehome Park Managemenl, Inc., Michael Ciril!o, Barbara Bames and Bctly 9 against Jade Bay Mobile Lodge, Inc., its officers, directors, employees, agents (including bu: n 8 fonh abovc, whether know or unknown, suspected Or unsuspected, thai Tenant may possess 7 obligations and other demands, including any relaling to the Mobile Home Value Claim as se b and completely release, remise and waive any all claims, actions, causes of action, liabil'i'"". 5 employees, agcnts, representatives, shareholders, affiliates, successors and assigns, hereby 4 respective successors and assigns and each of them, and his/her respective officers, director:, 3 Upon Tenant's receipt of the Settlement Funds as defined in Paragraph 10 below, Tenant, hlS. KENNETH KUBOTA . ROBERT KUBOTA, ETC CLASS 4 ACCOUNT P11 71 +-545.8332 17:i30 NEWHOPE ST. STE G FOUNTAIN 'VALlEY, CA 9VC6 11:1-49.:l5 W ~1001:>>l. oATZ_1-25-0.L... 2042 'iuy Or ~L; PAY TO nu; ORO~f'l QF__ ----.J $:_~_, ~.1? .?15, . 06 / 1 Qj~!LL,^S 8 =~::. .eb:o,"s o 1'. five hundred fifteen and I, Ei ght thousand. UNION BANK OF CALIFORNIA Ai:lJ,.I.U.....",,.,Vl ~ ~ 6 aa99 ~ AVI., Hu-m~QTCt-I tlv.<::l'\. ca. n -4 GOO 2J.S 044!l6 Space C-3 roper1/ SIGNATURE BANXlNG ---~~--~_..._._~ y 11 t S MeMO :3S0r: 2d lotJ""Ler r-" -.......A......' .....111.,,'-1. :'1 UA general release does not extend to claims which the credilor does not know or su.spe:t to exist in his favor at the time of executiog the release, which if known by him must 113'.'C . materially affectw his settlement with the debtor." 22 23 10. 24 111 exehmge for the above consideration from Tenant, including the releases specified in Paragraph 8 and 9 abOYe, the Claim Assignee has agreed to pay (0 Tenant the sum of , 25 26 27 ! 2 8 ~ I monlna - Januar;, and February 2007) for Tenant's conrinued occupancy at the Park from the delle estimated rent and utilities in the amount of5984 04 ($342.02 rent, $J 50.00 uliJllios, for two $8.515.06, representing Tenant's MobiJehome Value Claim in the amount ofS10,OOO.00, less hereo[through February 28, 2007, less a holdback (the "Holdback') in the amount of5500.00 (in 4J <;:202 ~ .4. 4-53 F'H,:;J.c:: 1':'; -=-:--c\.:.:u, Fr='I ~::.ll:22F'I"\ 10: '--' \, v obligatio"', liabilrtieoJ, dem.1..'\Da, claims, CO"'" exptM"", debts, controversie9, damages, rightl, 2. actions, or causes of action re\caso:l punuant to t.hil Agreement. Tne Parci~ also agree to defend; J inckmnif'y and hold one anotber hannlm a,gainst IlJ\Y obliglltion, \lability, demand, claim, cost, 4 o<pe:1&O (including but not limited to a:llorney9' fees incurred), debt, CDntroversy, damage, action 5 or ""use ofaction based on, aricing out cforin connection with any sucb sale, trans[";' cr =~~!L~ =/;''',-'''.0= 6 7 as signment or purported sal e, lnm sfer or assignment. DATED: D=mber J5.., 2006 xJlf"~,dq. ~ ..... f -. Mr. W~Uj~ Sap!, [T01Wrt] -=-;>>=- s 9 DATED: D=::mOer ~ 2006 SHIPMENTNQ SHIPMENT DATE WEIGhT 30873b '44513 20 Y d..l-'6-3ll'L/ IT IS S~'fiUl.D. DATED; ! !oft, 21 22 23 24 PRESHfl RINGST) KENNETH KUBOTA ROBERT KUBOTA, ETe CLASS 4 ACCOUNT PH. 714-545-6332 17330 NEWHOPE ST. STE G FOUNTAIN VALLEY, CA 92708 2S ByN rm General In aM Debto JABE M Ei2ht..tc12ousand 26 27 PAY TO THE W ORDER OF __--=- ~.9 xi!? .n~ tfJ" ~ P / }. iUiam Sapp [T (j ~~ Kenneth Kubota, ClaimAssignco RINGSTAD&S~~~LP_~ . , By. ~~'~~'lo.# 8 . GenmJ l.n.S<JJvcocy Counsd fo:r Ddrtor An cbtor- ~ ffi in-Po,-,,,,,,jon, JADE BAY MOBD..E LODGE, mc. a z w ~ ~ S ~ ORDER 'l" entirety. '-~t?I THE HONORABLE ERITHE A SMITH o 16-49 J~ 1220 0Cl51()SI JI).l 12-22-06 DAT= ~_____"__ --..---. 2001 _________~ ____n.._ ...__J $ 8,615.96 5 ix.._hundre.i.....Ui teen an,L9~i 1 0 Q DOL""' 6",;'::' UNION BANK Of CALifORNIA ACl,>.>.<.S AVEMU! #35 68'19 AD.......u Avt" HU"TIl"G10H BU.Cj1, CA 9'2o.olb aoo 2J8 01486 MEMO_.. ..? P9-~.~ _A=--~.z.___.___..__ 4-54 SIGNATURE BANKlNG ~~~ , I I -o~ -..-) I M' ATTACHMENT 6 CHAPTER 9.40 CHULA VISTA MUNICIPAL CODE i "455'5 Chula Vista Municipal Code 9.40.010 Chapter 9.36 DISCHARGING WEAPONS' Sections: 9.36.010 9.36.020 Prohibited generally. Exception. * For statutory provisions concerning control of con- cealed weapons, see Pen. Code S 12000, et seq. 9.36.010 Prohibited generally. It is unlawful for any person to shoot or dis- charge any gun or frrcarm, when the same is loaded with any shot or bullet, which will be, by such dis- charge, discharged therefrom, within the corporate limits of the city. (Prior code S 20.16). 9.36.020 Exception. Notwithstanding the general prohibition in CYMC 9.36.010, it shall not be unlawful to shoot or discharge any gun or firearm in that portion of the incorporated territoty of the city ofChula Vista generally west of the Lower Otay Reservoir described as follows: That portion of said city of Chula Vista ly- ing southerly of a line drawn from the east- ern edge of Wueste Road along the south- ern edge of Gtay Lakes Road east to the 480-foot contour line along the western edge of the Lower Gtay Reservoir; follow- ing the 480-foot contour line southerly along the western edge of the Lower Gtay Reservoir coincident with the southerly edge of the Chula Vista city limits; from there west to the eastern edge of Wueste Road and northerly again to the point of or- igin along the eastern edge of Wueste Road. Such shooting or discharge shall only be lawful for patrons of the city of San Diego's Water Fowl Hunting Program, for the purposes of seasonal duck hunting (between October and January of each year, as specified in that program). (Ord. 2370 S 1,1990). LX. Mobilehome Park Residence Protection Chapter 9.40 HOUSING ASSISTAl'lCE Sections: 9.40.010 Mobilehome park and trailer park conversions - Purpose and intent. Defmitions. Application for conversion or discontinuance of mobile home or trailer park. 9.40.020 9.40.030 9.40.010 Mobilehome park and trailer park conversions - Purpose and intent. It is the purpose of the city council in accordance with the provisions of Sections 65863.7 and 66427.4 of the Government Code of the state to mitigate any adverse impact of the conversion of mobi1ehome and trailer parks to other uses or the discontinuance of use of mobilehome Of trailer parks on the ability of displaced mobi1ehome or trailer owner/occupants to fmd adequate spaces in other such parks. It is the intent of the council to impose upon park owners choosing to convert or discontinue their mobilehome or trailer park oper- ations, whether located in exclusive mobilehome park zones or in other commercial or resi?ential zones, the obligation to provide financial aSSistance or some satisfactory alternative thereto for those mobilehome or trailer owner/occupants who would be dislocated by the decision to convert such mobilehome or trailer parks to uses other than that designated in the zone, or than that to which they have been utilized, or to discontinue use. It is the intent of this chapter to carry out and supplement the requirements of the state law in regard to noti- fication and to establish relocation assistance pro- grams for low- and moderate-income mobilehome or trailer owner/occupants placed in the position of being dislocated as a result of either conversion of mobilehome parks to other uses or discontinuance of use. This section does not apply to mobilehome or trailer owner/occupants who move into mobile- home or trailer parks where the park owner has pro- vided said mobilehome or trailer owner/occupant with written notification at the time they move in of intention to discontinue the mobilehome or trailer park on a specific date within three years of that written notification. (Ord. 2299 S 1, 1989; Ord. 1982 S 1, 1982). 9-43 4-56 9.40.020 9.40.020 Definitions. A. "Mobilehome" is a structure designed for human habitation and for being moved on a street or highway under permit pursuant to Section 35790 of the California Vehicle Code. "Mobilehome" includes a manufactured home, as defined in Sec- tion 18007 of the Health and Safety Code, and a mobilehome, as defined in Section 18008 of the Health and Safety Code, but does not include a rec- reational vehicle, as defined in Section 799.24 of the California Civil Code and Section 18010 ofthe California Health and Safety Code. B. "Mobilehome park" is an area of land where two or more mobilehome sites are rented, Of held out for rent, to accommodate mobilehomes used for human habitation, and where the predominant number of sites are occupied for nine or more con- secutive months. C. "Trailer," for the purpose of this chapter only, is a structure designed for human habitation and for being moved on a street or highway without need for a permit pursuant to Section 35790 of the California Vehicle Code. "Trailer," for the purpose ofthis chapter only, does not include the following recreational vehicles as defmed in Section 799.24 of the California Civil Code: motor homes, slide-in campers, truck campers, and camping trailers. "Trailer," for the purpose of this chapter only, does include the following recreational vehicles, as defined in Section 799.24 of the California Civil Code: travel trailers. D. "Trailer park," for the purpose of this chap- ter only, is an area of land where two or more trailer sites are rented, or held Qut for rent, to accommo- date trailers used for human habitation, and where the predominant number of sites are occupied for nine or more consecutive months. E. "Mobilehome or trailer owner/occupants" are persons owning and occupying a mobilehome or trailer as their principal residence for six months or more during a year. (Ord. 2368 Ij I, 1990; Ord. 22991j I, 1989). 9.40.030 Application for conversion or discontin,~ance of mobilehome or trailer park. A. Application for Conversion or Discontinu- ance. Prior to the approval of any rezoning, subdi- vision map, or the issuance of any permit, including a building pennit, which would allow the use of any properties presently or hereinafter uti- lized for mobilehome or trailer parks to be used for any purpose other than a mobilehome or trailer park, or prior to the cessation of use of all or any part of a mobilehome or trailer park, an application to convert from such use or to discontinue must be filed with the community development depart- ment. The requirements of this section shall be applicable whether or not the mobilehome or trailer park is: 1. Located within an exclusive mobilehome park zone; 2. Located within a zone subject to condi- tional use pennit; or 3. Entitled to be used as a'mobilehome or trailer park based on nonconfonning rights. B. Application Requirements. The following information or documentation shall constitute application for conversion or discontinuance of an existing mobilehome or trailer park. I. A relocation plan which shall make ade- quate provision for the relocation of the mobile- home or trailer owner/occupant who will be displaced by the discontinuance of the use of the property for a mobilehome or trailer park; 2. A profile of the existing park, including: a. Number of spaces, b. Names and addresses of all mobile- home or trailer owner/occupants, c. Date of manufacture of each home, d. Replacement value of each home, e. Estimated cost of relocation of each home, f. Length of tenancy of each mobilehome or trailer owner/occupant, g. Estimated income and age of each mobilehome or trailer owner/occupant; 3. A timetable for vacating the existing park; 4. Evidence satisfactory to the community development director that agreements satisfying the relocation assistance requirements of this chap- ter have beel1 offered to eligible mobilehome or trailer owner/occupants. Such evidence may include, but is not limited to, the following: a, Written agreements to relocate mobile- homes or trailers owned by low- and moderate- income mobilehome or trailer owner/occupants, b. Assistance for low- and moderate- income mobilehome or trailer owner/occupants in the form of payment by the park owner of 75 per- cent, up to a maximum of $3,000, of the cost of relocating the mobilehome or trailer to another mobilehome or trailer park within 100 miles; 5. Evidence that the park owner has informed all mobilehome or trailer owner/occupants in writ- ing of alternative sites available to them; 6. Evidence that the park owner has agreed to purchase those homes of low- and mnderate- 9-44 4-57 Chula Vista Municipal Code 9.40.030 income mobilehome or trailer owner/occupants which are determined to be not relocatable due to age and/or condition. Such purchases shall be based on standard insurance replacement criteria; 7. Evidence that the displaced residents have been provided right of first refusal to purchase, lease or rent any dwelling units or mobilehome or trailer spaces which may be built on the subject property; 8. A narrative summary of planned new use of property to be converted Of reason for non-use; 9. As an alternative to subsection (B)(4)(b) of this section, evidence that the park owner has given the mobilehome or trailer owner/occupants a three-year notice to vacate, said notice being pur- suant to Section 798.56(f) of the Civil Code. If such a three-year notice is given, the applicant must assist all low- and moderate-income dis- placed mobilehome or trailer owner/occupants in accordance with the following schedule: If Mobilehome or Trailer Owner/ Occupant Vacates Before End of First year Second year Third year Portion of Expenses Paid Up to a by Owner Maximum of 75% $3,000 50% $2,000 25% $1,000 C. Submittal to and Decision ofthe Community Development Director. All of the above applica- tion information shall be submitted to the commu- nity development director. The community development director shall make his decision in the following manner: 1. If the community development director determines that the application is complete and conforms with all regulations, policies and guide- lines, and that the relocation plan or other commit- ments by the park owner mitigate the impact of conversion or discontinuance on the health, safety and general welfare of persons residing in the mobilehome or trailer park, he shall grant the appli- cation for conversion. 2. If the community development director detennines that the application is not complete or it does not conform with all regulations, policies and guidelines, or that the relocation plan or other com- mitments by the park owner do not mitigate the impact of conversion or discontinuance on the health~ safety or general welfare of persons resid- ing in the mobilehome or trailer park, he shaH deny the application for conversion. 3. The communitY development director may establish the date on which the resolution of conversion or discontinuance will become effec- tive. Such date shall not be more than three years from the date of decision of the community devel- opment director, or such earlier date as the appli- cant has complied with the provisions of an approved relocation plan and submitted evidence thereof to the community development director. 4. In granting or denying the application for conversion or discontinuance of the mobilehome or trailer park, the community development direc- tor shall make a written finding in rendering the decision and shall fully set forth wherein the facts and circumstances fulfill or fail to fulfill the requirements set forth herein. 5. A copy of this written finding of facts shall be filed with the city clerk and the director of planning and building, and shall be mailed to the applicant and to the mobilehome or trailer owner/occupants of the mobilehome or trailer park. 6. The decision of the community develop- ment director shall be fmal on the fifteenth day fol- lowing the mailing of the decision to the applicant and the mobilehome or trailer owner/occupants required in subsection (C)(5) of this section, except when appeal is taken to the city council as provided in subsection (D) of this section. D. Appeal from the Decision from the Commu- nity Development Director. 1. An appeal from the decision of the com- munity development director on an application for conversion or discontinuance of a mobilehome or trailer park may be taken to the city council within 15 days foHowing the decision of the community development director. The appeal may be taken by the applicant, any govemmental body or agency, any owner of real property located within the city or any resident of the city. The appeal shall be in writing on a prescribed form and filed with the city clerk. The appeal shall specifY wherein there was an error in the decision of the community develop- ment director. If an appeal is filed within the time specified, it shall automatically stay proceedings in the matter until a determination is made by the city council. 2. Upon the filing of the appeal, the commu- nity development director shall set the matter for public hearing before the city council at the earliest practicable date. The public hearing shall be noticed and held in accordance with the provisions of this code. Notice of time and place and purpose of such hearing shall be given as follows: 9-45 4-58 9.40.030 a. By at least one publication in the offi- cial newspaper of the city, not less than 10 days prior to the date ofthe hearing; b. By mailing notices at least 10 days prior to the date of such hearing to the mobilehome or trailer park owner and to all mobilehome or trailer owner/occupants of the mobilehome or trailer park. 3. Upon the hearing of the appeal, the city council may by resolution affirm, reverse or mod- ifY in whole or in part any determination of the community development director, subject to the same limitations as are placed upon the community development director by law and the provisions of this code. The resolution must contain a finding of fact showing wherein the proposed development meets or fails to meet the requirements herein. 4. The decision of the city council shall be final unless appealed to a court of competent juris- diction. E. Waiver. The community development direc- tor may recommend to the city council the accep- tance of other mitigating actions by the park owner in lieu of the specific provisions herein if extreme economic hardship would result for the park owner, or if other proposed mitigating actions have recommending benefit. F. Notification Requirements. In addition to any notification requirements under the California Civil Code, the following notification requirements shall apply to any application for conversion or discon- tinuance of mobile home or trailer park use: 1. A minimum of 10 calendar days prior to an applicant filing an application for conversion or discontinuance of the mobilchome or trailer park, the applicant shall give written notice to each mobilehome or trailer owner/occupant of the rnobiIehome or trailer park of the proposed change. Such notice shall be subject to the prior approval of the community development director. 2. No public hearing required hereunder to consider an application for conversion or discon- tinuance of a rnobilehome or trailer park use shall be held unless and until the applicant submits to the community development director an affidavit approved as to form by the city attorney declaring that the applicant has given the notice required by this provision. G. Penalty. Violation of any provision of this chapter by the owners of mobilehome or trailer parks shall be deemed to be a misdemeanor subject to the penalties as established by state law for mis- demeanors. In addition thereto, any mobilehome or trailer owner/occupant in a mobilehome or trailer park where conversion to other uses or discontinu- ance has been sought or accomplished, and in which violations of the terms and provisions of this chapter have occurred, may seek civil remedies for damages in accordance with the relocation provi- sions contained herein, no later than one year from the date of lease cancellation or eviction from the rnobiIehome or trailer park. (Ord. 2790, 1999; Ord. 2368 S 2, 1990; Ord. 2299 S I, 1989). 9-46 4-59 ATTACHMENT 7 SECTION 7.17 LAND USE AND TRANSPORTATION ELEMENT CHULA VISTA GENERAL PLAN 4-60 7.17 - Evaluations for Mobilehoroe Developments: IYlobilehome Overlav District As noted in LUT Section 7.1 and in Housing Element Part L Section 3.0. maintaining an adequate sunnlv of land desigoated aod zoned at anpropriate densities to sunport a variety of residential housing tvnes is an imnortant corononent of ensuring sufficient diversity and balance to meet the needs of existing and future residents. In Chula Vista. mobilehome developments have historicallv been a nart of that supplv. and have effectivelv provided a unique and affordable housing source. Housing costs for mobilehome Jiving are often lower than market rates for other types of housing such as comparable sized rental apartments. As such. it is not uncommon to find that manv of the households residing in mobilehome developments are living on fixed incomes. or are otherwise in need of lower-income affordable housing. Additionallv. manv'residents own their own coach. but rent or lease the land space. leaving them vulnerable to changes in land use. These circumstances can present added challenges in finding suitable replacement housing options for mobilehome residents in the event of potential closure of one or more of these developments. As shown on Figure 5-l8(A). there are currentlv 32 mobilehome developments within the City in a variety of settings ranging from well organized and maintained parks with exclusive Mobile Home Park (MHP) zoning. to less formal and often smaller trailer parks in areas zoned for commercial or other development. Within the Urban Core Subarea. several mobilehome developments fall within the Interstate 5 Corridor District where higher density housing and transit-focused mixed uses are envisioned to OCCur. With increasing housing demands and rising land costs throughout the region. the likelihood for potential closure of some mobilehome developments over time is real. In recognition of these circumstances. and in order to better balance the often unique needs of mobilehome residents with the challenges in locating suitable replacement housing. it is important that analvsis and planning be undertaken in accordance with the principles of the Housing Element obiectives prior to the Citv's consideration of anv requested change in use and/or rezoning affecting any of the existing mobilehome sites. In order to accomplish this. the Mobilehome Overlav District is established to ensure that the appropriate evaluation and consideration of the affects of potential changes in use and/or urban redevelopment on this unique form of housing from the standnoints of housing opportunity. affordability. and displacement replacement and/or relocation assistance is conducted in accordance with the principles et forth in the Housing Element and the Municinal Code. As stated in the following Objective and Policies. the Mobilehome Overlav District ensures that the analysis and planning on the affects of closure on existing mobilehome residents is conducted and that the propertY owner and/or proiect proponent has prepared and carried out a plan to address those affects as required bv the Municipal Code. 4-61 Obiective - LUT 34.A Ensure sufficient evaluation and response to the effects of any change of use or urban redevelopment of existing mobilehome developments. Policies LUT 34.A.l Prior to the City's consideration of anv proposed change of use and/or rezoning pursuant to Municiual Code Chapter 9.40 of any mobilehome development properties within the City as identified on Figure 5-18! A). the property owner and/or proiect proponent shall prepare a ulan in conformance with applicable State and City regulations including Municipal Code Chanter 9.40. and to the satisfaction of the Director of Planning al1d Building and the Director of Community Development that provides steps and urovisions to mitigate any adverse impacts of the conversion on the affected residents. LUT 34.A.2 At the time of consideration of any change of use and/or rezoning of any of the mobilehome uroperties noted above. the City Council shall review the nlan prepared under Policy 34.A.L and nrior to taking action on said change of use and/or rezoning in accordance "ith the requirements of Municinal Code Chanter 19.06 and section 19.12.020. shall make the following findings: . That the proposed change of use and/or rezoning will not adverselv affect attainment of the City's goal to nrovide a variety of housing outions within the City. !Housing Element Obiective 3) . That the proposed change of use and/or rezoning is supoorted bv sound plarning principles. and higher density. affordable replacement housing within the City will remain in sufficient suuplv. !Housing Element Obiective 3) . That the property ov,oer and/or proiect PTouonent plan does ensure sufficient evaluation and response to the effects of the change of use and/or rezoning of the existing mobilehome development. !Housing Element Obiective 4) . That the proposed change of use and/or rezoning will not result in severe or undue hardship on affected mobilehome residents. !Housing Element Obiective 4) . That the property ov,oer and/or moject proponent plan complies with applicable City and State mobilehome conversion and relocation regulations. !Housing Element Obiective 4) . That prior to the commencement of anv closure of the mobilehome development. that the property owner! s) will prepare and ensure performance of a detailed closure and relocation plan consistent with the requirements of CYMC Section 9.40 and applicable State regulations. and to the satisfaction of Directors of Planning and Building and Community Development. 4-62 Mobne Home Overlay !D8strict ~1;;;,Ht;< -1>0 I a> w LEGEND ,,"......./ General Plan 8ou'ndary /............/. City Boundary I!:ilE9 Mobile Home Overlay District Areas A ....,~ :l: .....- 1 ~ L~:'~{~ r"-u-,,-,,-,,- .~ _.I ! I -----..1.-_ r-I _1 _ .. I \. I _.....-~J /1 - I I I ~_I __-.J ......--.::_~ LI : NORTH N.T,S. Figure 5-18A Existing Mobile Home Parks In Overlay District 1 Chula Vista Mobile Home Park 2 Jade Bay Mobile Lodge 3 Bayscene Mobile Home Park 4 Fogerty Brothers Trailer Park 5 Caravan Trailer Park 6 Trailer Villa 7 Terry's Mobile Home Park 8 Mohawk Trailer Park 9 Terry's Broadway Trailer Park 10 Rose Arbor Mobile Horne Park 11 Cabrillo Mobile Lodge 12 Flamingo Trailer Park 13 Bison Mobile Home Park 14 Sharon's Trailer Park 15 Brentwood Mobile Home Park 16 Mountain View Mobile Lodge 17 Georganna Trailer Park 18 Bayside Trailer ParI< 19 Rancho Bonita Mobile Home Park 20 El Mirador Trailer Court 21 Orange Tree Mobile Home Park 22 Continental Country Club 23 Hacienda Mobile Estates 24 Lynwood South Mobile Home Park 25 Farmhouse Trailer Park 26 Granada Mobile Estates 27 Thunderbird Mobile Home Park 28 Fabulous Caliente Mobile Home Park 29 Palm Mobile Estates 30 Palace Gardens Mobile Home Park 31 Don Luis Estates 32 Otay Lakes Lodge Page LUT-130D ~\If?- ~.1-- 1]IYOf Cl-UJLAVISTA ATTACHMENT 8 MEETING MINUTES PLAL~~G COMMlSISON 4-64 MINUTES OF THE PLANNING COMMISSION OF THE CITY OF CHULA VISTA 6:00 p.m. June 24, 2009 Council Chambers 276 Fourth Avenue Chula Vista, California CALL TO ORDER: ROLL CALL I MOTIONS TO EXCUSE: Members Present: Member Absent: Clayton. Moctezuma, Vinson, Spethman, Thompson Tripp, Felber MSC (ClaytonIMoctezuma) to excuse Cmrs. Tripp and Felber. Motion carried. INTRODUCTORY REMARKS: Read into the record by Vice-Chair Clayton ORAL COMMUNICATIONS: No public input. CONSENT AGENDA: PUBLIC HEARING: 1. Public Hearing: PCZ 08-04; Consideration of an application filed by SKK Realth, LLC requesting a rezone from MHP-Exclusive Mobilehome Park to R3 Apartment Residential Zone with a Precise Plan Modifying District. 6:07:54 PM Background: Jeff Steichen reported that this is a request for a rezone to change the existing Mobilehome Park zoning designation to R-3-P, Apartment Residential with a Precise Plan Modifying District, for a 4.35-acre vacant site located at 701 D Street in northwest Chula Vista. The rezone would bring the zoning for the site into conformity with the existing General Plan designation of Residential High (multi-family). The project site waS the former Jade Bay Mobile Home Park, established in 1960 at which time the zoning was R-3. On November 28, 1978 the City Council established the MHP Zone and in June 1980 the subject property was changed from R-3 to MHP. Following the conclusion of bankruptcy proceedings, the court exercised its jurisdiction to effect the park closure in 2006. Staff Recommendation: That the Planning Commission adopt Resolution PCZ 08-04 recommending that the City Council adopt the Draft City Council Ordinance and Resolution. 4-65 Planning Commission Minutes -2- June 24, 2009 Commission Discussion: A discussion ensued between Cmr. Thompson and Deputy City Attorney Miller regarding the bankruptcy proceedings and the application of the City's Mobilehome Park Closure Requirements under Chapter 9.4 of the Municipal Code, which outlines criteria requiring a relocation plan far residents of an existing mobilehome park and approval of the plan prior to considering the closure of a park and subsequent rezoning of the property. 6: 16:09 PM 6:22:36 PM Cmr. Thompson stated he understands that the P-modifier allows fiexibility in addressing the unique characteristics of the property in relationship to its surroundings, but is of the opinion that perhaps instead of the P-modifrer designation, the same thing could be accomplished through the Variance process. Jeff Steichen responded that in light of the diversity of existing land uses surrounding the property, staff believes that the application of the P-modifier will allow greater design control over the eventual development of the site to insure compatibilily with existing uses surrounding the site. Staff also felt that it was prudent to include the P designation because there are some unique situations i.e. the site is accessed off of two streets and is at the terminus; the P-modifier allows flexibility in addressing other deviations in development standards i.e. height, signage, parking and setbacks. Public Hearing Opened. 6:29:46 PM The following members of the public spoke during public testimony in opposition of the rezone and urged to Commission to vote against it : DeanSpooner.6:30:06 PM Barbara Nunnelec 6:36:28 PM Patricia Lopez 6:42:32 PM Theresa Acerra 6:46: 11 PM Dolores Dempsey .S:" , The following members of the public spoke during public testimony in support of the rezone and urged the Commission to vote in support of it: Ed Herrera 6.33:20 PM Lisa Cohen 6:45:01 PM 6:52:33 PM Jeff Chine, representing the applicant stated he understands there are deep emotions surrounding the history of this property as well as complex issues with the Federal Bankruptcy Court over matters of jurisdiction. The issue at hand is what is in the best interest of the citizens of Chula Vista with regard to the zoning designation of this piece of property; the proposed rezoning better implements the General Plan land use designation than its current zoning. SKK Realty is seeking the rezone to make this a productive piece of property that will eventually be developed with a stellar infill project that complies with all City standards: including inclusionary housing. Staff and the City Attorney have done a thorough analysis of the proposal and he would urge the commission to move forward with recommending approval of the rezone. Public Hearing Closed. 7:03:05 PM 4-66 Planning Commission Minutes .3- June 24, 2009 Commission Comments: 7:03: 18 PM Cmr. Vinson stated that the conditions leading to the closure of the park through bankruptcy court are not under consideration by the Planning Commission at this time. He further indicated this is a blighted parcel in its current condition and is being used as a dumping site; he is hopeful that a development proposal will come sooner than later providing inclusionary housing, property tax revenue, and construction jobs, therefore, he is supporting the rezone. 7:05:56 PM Cmr. Clayton asked how does an affirmative vote on the rezone affect the resident protection afforded under the City Code to other mobilehome parks in the city. Steve Power responded that this is an independent action on a vacant piece of land; the 9.4 prOVisions apply to all existing operating and occupied mobilehome parks. David Miller added that unless there is some adjudication by a federal or State court, all City rules and regulation contained in our code would have to be followed. 7:07:34 PM Cmf. Spethman stated he concurs with emf. Vinsons' comments and empathizes with the plight of the residents who were displaced because of the bankruptcy proceedings, however, the current conditions of the site don't help anyone and is an eye- sore to the community; the City has to be forward-thinking and create the conditions that will lead to the highest and best development of the site. 7:11:18 PM MSC (VinsonfSpethman) (4-1-0-2) to support including the P modifier. Motion passed with Gmr. Thompson voting against it. 4:"'67 ATTACHMENT 9 OWNERSHIP DISCLOSURE FORM 4-68 ~N?- -~ @' - - p I ann n g & Building Planning Division Department Development Processing CI1Y OF CHULA VISTA APPLICATION APPENDIX B Disclosure Statement Pursuant to Council Policy 101-01, prior to any action upon matters that will require discretionary action by the Council, Planning Commission and all other official bodies of the City, a statement of disclosure of certain ownership or financial interests, payments, or campaign contributions for a City of Chula Vista election must be filed. The following information must b" disclosed: 1. List the names of all persons having a financial interest in the property that is the subject of the application or the contract, e.g., owner, applicant, contractor, subcontractor, material supplier. SKK Realty, LLC 2. If any person* identified pursuant to (1) above is a corporation or partnership, list the names of all individuals with a $2000 investment in the business (corporation/partnership) entity. SKK Realty. LLC 3. If any person* identified pursuant to (1) above is a non-profit organization or trust, list the names of any person serving as director of the non-profit organization or as trustee or beneficiary or trustor of the trust. 4. Please identify every person, including any agents, employees, consultants, or independent contractors you have assigned to represent you before the City in this malter. MAY Group. Inc. foe ...ts( cYY' , r1C . 5. Has any person* associated with this contract had any financial dealings with an official** of the City of Chula Vista as it relates to this contract within the past 12 months. Yes_ No2-- If Yes, briefiy describe the nature of the financiai interest the official** may have in this contract. , Not Applicable 6. Have you made a contribution of more than $250 within the past twelve (12) months to a current member of the Chula Vista City Council? No ~ Yes _If yes, which Council member? 276 Fourth Avenue Chula Vista QI>W~nia 91910 (619) 691-5101 ~\!y ~ ~ - p I ann n g & Building Planning Division Department Development Processino o CITY OF CHUIA VISTA APPLICATION APPENDIX 8 Disclosure Statement - Page 2 7. Have you provided more than $340 (or an item of equivalent value) to an official" of the City of Chula Vista in the past twelve (12) months? (This includes being a source of income, money to retire a legal debt, gift, loan, etc.) Yes NOL- If Yes, which official" and what was the nature of item provided? Date: \ '2- \ 1 "Ii' \ 0"1 (p1?J jlit f ' ~f\'\('v,,"^,"v~ i\--l\ I' Signature of Contractor/Applicanf ' Marwan A. Younis type name of Contractor/Applicant Print or * Person Is defined as: any individual, firm, co-partnership, joint venture, association, social club, fraternal organization, corporation, estate, trust, receiver, syndicate, any other county, city, municipality, district, or other political subdivision, -or any other group or combination acting as a unit. ** Official includes, but is not limited to: Mayor, Council member, Planning Commissioner, Mem!:Jer of a board, commission, or committee of the City, employee, or staff members. 276 Fourth Avenue Chula Vista ~a.Lr1'O n i a 91910 (&19) 691-5101 :'--j RESOLUTION NO. RESOLUTION OF THE CfTY COUNCIL OF THE CITY OF CHULA VISTA FINDING THAT APPLICANT HAS COMPLIED WITH REQUIRED PROVISIONS OF LUT SECTION 7.17 OF THE CHULA VISTA GENERAL PLAN REGARDING AN APPLICATION TO REZONE PROPERTY CURRENTL Y DESIGNATED MHP (EXCLUSIVE MOBILEHOME PARK) ZONE WHEREAS. the subject matter of this Resolution is the Zoning Map established by Chapter 19.18.010 of the Chula Vista Municipal Code. The area of the Zoning Map to be used as the project area is depicted on Attachment "A"; and WHEREAS, an application to amend the Zoning Map was made by SKK Realty, LLC ("Applicant") and filed with the City of Chula Vista Development Services Department on June 9,2008; and WHEREAS, the applicant proposes to rezone the 4.35 acre property located at 701 D Street ("Project Site") from the MHP (Exclusive Mobilehome Park) Zone to the R-3-P (Apartment-Residential, Precise Plan) Zone, establishing a Precise Plan Modifying District, ("Project"); and WHEREAS, the General Plan requires that prior to rezoning any property within the Mobilehome Overlay District, specific findings must be made to insure that analysis and planning on the atlects of closure of existing mobilehome residents has been conducted; and WHEREAS, The Environmental Review Coordinator has reviewed the proposed project for compliance with the California Environmental Quality Act (CEQA) and has determined that since the proposed rezone was adequately covered in previously adopted General Plan Update Final Environmental Impact Report, EIR 05-01, no further environmental review or documentation is necessary; and WHEREAS, the Planning Commission recommended approval of the project at a public hearing held at a time and place advertised, namely 6:00 pm on June 24, 2009, in the Council Chambers, 276 Fourth Avenue; and WHEREAS, a City Council hearing on the project was noticed for July 14, 2009, and was continued to a date uncertain; and WHEREAS, the applicant requested that further action on the application be placed on hold until a later date; and 4-71 Resolution No. Page 2 WHEREAS, on or about June 6, 2010, Applicant requested that the matter be moved forward to a hearing before the City Council for a decision; and WHEREAS, the City Clerk set the time and place for a hearing on said zone change (PCZ-08-04) and notice of said hearing together with its purpose was given by its publication in a newspaper of general circulation in the city and the notice was mailed to property owners within 500 feet of the exterior boundaries of the Project site at least ten days prior to the hearing; and WHEREAS, the hearing was held at the time and place as advertiscd, namely 4:00 p.m. on August 10, 2010, in the Council Chambers located at 276 Fourth Avenue, and said hearing was thereafter closed. NOW, THEREFORE, BE IT RESOLVED THAT THE City Council hereby finds that the following findings have been made: THAT THE PROPOSED CHANGE IN USE AND/OR REZONING WILL NOT ADVERSELY AFFECT ATTAINMENT OF THE CITY'S GOAL TO PROVIDE A VARIETY OF HOUSING OPTIONS WITHIN THE CITY. The proposed change in use/rezone will not adversely affect the City's housing goals since the project site is currently vacant and, therefore, does not currently contribute any units towards the housing stock. Since the development of the Jade Bay Mobile Lodge there has been a greater diversity of housing types developed for a variety of income limits within Chula Vista, offering more varied housing options. Rezoiling of the property to allow for multi-family development will help achieve the City's goal of achieving a variety of housing types. This will help achieve the goal of General Plan Policy LVT 1.9, which is to provide opportunities for devclopment of housing that respond to diverse community needs in terms of density, size, location and cost. Multi- family allows for either rental or condominium units to be developed on the site. Typically, the rents or sales prices for these units would be lower than that of a single- family dwelling. The City's General Plan land use designation for this site is currently High Density Residential so that the rezoning would result in the existing zoning to be brought into greater conformance with the General Plan. Further, this would help achieve the City's General Plan policy of achieving a variety of housing options. Policy I,.VT 1.19 requires that land use intensities be evaluated in conjunction with any zone change and/or General Plan Amendment to permit density or modify intensity. Factors to be considered include, but are not limited to, the maximum intcnsity allowed for the applicable land use designation in the General Plan, traffic circulation patterns, environmental constraints, and compatibility with surrounding land uses. The requested rezone to R-3 is the most consistent zone with the existing RH designation of the General Plan. 4-72 Resolution No. Page 3 nIE PROPOSED CHANGE OF USE AND/OR REZONING IS SUPPORTED BY SOUND PLANNING PRINCIPLES, AND HIGHER DENSITY, AFFORDABLE REPLACEMENT HOUSING WITHIN THE CITY WILL REMArN IN SUFFICIENT SUPPL Y. The General Plan designation for the project site is RH that allows for multi-family development at a density range of 18-27 dwelling units per acre, a higher density than is typical for a mobilehome park type development. Thus, the proposed change to R-3 zoning is consistent with the City's desire for higher density development in the area. Any future development will be required to comply with the City's Balanceu Communities ("Inclusionary") I-lousing Element Policy for affordable housing. As stated in General Plan Policy H5.1, newly constructed residential development projects containing 50 or more units, shall include a minimum of 10% as affordable housing. Since the proposed zoning will allow for multi-family housing consistent with the high density designation of the General Plan, it will provide for more affordable housing units than other types of residential development. Future development of the site will provide housing opportunities to many in the form of affordable rental or ownership units due to the inclusionary policy mentioned above. THAT TI-IE PROPOSED CHANGE OF USE/AND OR RESULT IN SEVERE OR UNDUE HARDSHIP MOBILEI-IOME RESIDENT. REZONING WILL NOT ON ANY AFFECTED There will be no undue hardship on "affected mobilehome residents" as there are currently no mobilehome home park residents to be "affected" by the rezone. All of the residents agreed to vacate the park, signeu contracts agreeing to accept the relocation benefits under the confirmed Chapter 11 plan as full settlement of any and all claims they had or may have in the future for relocation benefits, and subsequently moved out of the mobile home park over three years ago. Additionally, the applicant has indicated that the previous tenant, Jade Bay, provided assistance above and beyond that required by the court. As the site is currently vacant, no residents will be affected by, nor suffer "severe or undue hardship" from the rezone; thus, this eonuition has been met. THAT THE PROPERTY OWNER AND/OR PROJECT PROPONENT PLAN COMPLIES WITH APPLICABLE CITY AND STATE MOBILE HOME PARK CONVERSION AND RELOCATION REGULATIONS. The St'lte mobile home park regulations addressing closure and rezone are expressly inapplicable in situations where the park operator is adjudicated bankrupt. Though such regulations are not applicable, the Federal Bankruptcy Court did ensure that the tenants received relocation benefits and that the park was closed in accordance with City of Chula Vista regulations to the extent possible. The tenants also agreed to sign a contract accepting the benefits as complete satisfaction of any claims they might have under state or local law. All residents did so. Most importantly, the requirement of a plan is only applicable in situations where there is an existing mobilehome park with residents. The 4-73 Resolution No. Page 4 site is currently vacant and no residents live on the site; therefore, this finding that the property owner and/or project proponent complies with applicable city and state mobile home park regulations has been met. THAT PRIOR TO TI-IE COMMENCEMENT OF ANY CLOSURE OF THE MOBILEHOME DEVELOPMENT, THAT THE PROPERTY OWNER(S) WILL PREPARE AND ENSURE CONFORMANCE OF A DETAILED CLOSURE AND RELOCATION PLAN CONSISTENT WITH THE REQUIREMENTS OF CVMC SECTION 9.40 AND APPLICABLE ST ATE REGULA nONS. AND TO THE SA TISF ACTION OF DIRECTOR OF DEVELOPMENT SERVICES. The specific requirement to prepare and ensure conformance of a detai led closure and relocation plan "prior to the commencement of any closure' is not applicable under the existing circumstances as the property owners are not requesting the closure of the Jade Bay Mobile Lodge. The park was closed previously through the federal bankruptcy proceedings. In addition, there arc no residents currently residing in the park; thus, there are no individuals to relocate or to which benefits would be due through this action. This finding is, therefore, inapplicable. Presented by Gary Halbert, PE, AICP Assistant City Manager/ Development Services Director 4-74 ORDINANCE NO. ORDINANCE OF THE CITY OF CHULA VISTA AMENDING THE ZONING MAP ESTABLISHED BY SECTION 19.18.010 TO REZONE ONE 4.35 ACRE PARCEL LOCATED AT 701 D STREET FROM MHP (EXCLUSIVE MOBILEHOME PARK) ZONE TO R-3-P (APARTMENT RESIDENTIAL, PRECISE PLAN) ZONE WHEREAS, the subject matter of this Ordinance is the Zoning Map established by Chapter 19.18.010 of the Chula Vista Municipal Code, and the area of the Zoning Map to be used as the project area is depicted on Attachment A; and WHEREAS, an application to amend the Zoning Map was made by SKK Realty, LLC ("Applicant") and filed with the City ofChula Vista Development Services Department on June 9, 2008; and WHEREAS, the 2005 General Plan designates the site as RH and the proposed zoning is consistent with the General Plan and is an implementing zone for this General Plan designation; and WHEREAS, the applicant proposes to rezone the 4.35 acre property located at 701 D Street ("Project Site") from the MHP (Exclusive Mobilehome Park) Zone to the R-3-P (Multi Family Residential, Precise Plan) Zone, establishing a Precise Plan Modi fying District, ("Project"); and WHEREAS, the Environmental Review Coordinator has reviewed the proposed project for compliance with the California Environmental Quality Act ("CEQA") and has determined that since the proposed rezone was adequately covered in previously adopted General Plan Update Final Environmental Impact Report, EIR 05-0 I, no further environmental review or documentation is necessary; and WHEREAS, the Planning Commission recommended approval of the project at a public hearing held at a time and place advertised, namely 6:00 pm on June 24, 2009, in the Council Chambers located at 276 Fourth Avenue; and WHEREAS, a City Council hearing on the project was noticed for July 14,2009, and at the request of staff.was continued to a date uncertain; and WHEREAS, the applicant requested that further action on the application be placed on hold until a later date; and 4-75 Ordinance No. Page 2 WHEREAS, on or about June 6, 20 I 0, Applicant requested that the matter be movcd forward to a hearing before the City Council for decision; and WHEREAS, the City Clerk set the time and place for a hearing on said zone change (PCZ- 08-04) and notice of said hearing, together with its purpose, was given by its publication in a newspaper of general circulation in the city, and the notice was mailed to property owners within 500 feet of the exterior boundaries of the Project site at least ten days prior to the hearing; and WHEREAS, the hearing was held at the time and plaee as advertised, namely 4:00 p.m. on July 27, 2010, in the Council Chambers located at 276 Fourth Avenue, and said hearing was thereafter closed. NOW, THEREFORE, the City Council of the City of Chula Vista does hereby ordain as follows: 1. FINDINGS FOR APPROVAL OF REZONE AND PRECISE PLAN MODIFYING DISTRICT. Pursuant to Section 19.56.041 of the Chula Vista Municipal Code, the City Council of the City of Chula Vista finds that the following circumstances are evident, which allows the application of the "P" Precise Plan Modifying District to the project site. 1. THE SUBEJCT PROPERTY, OR THE NEIGHBORHOOD OR AREA IN WHICH THE PROPERTY IS LOCATED, IS UNIQUE BY VIRTUE Of TOPOGRAPHY, GEOGRAPHICAL CHARACTERISTICS, ACCESS, CONFIGURATION, TRAFFIC CIRCULA nON OR SOME SOCIAL OR HISTORICAL SITUATION REQUIRING SPECIAL HANDLING OF THE DEVELOPMENT ON A PRECISE PLAN BASIS. The City Council finds that the proposed P-modifier will provide necessary safeguards so that at the time of future development of the site, consideration will be made ofthe unique characteristics of the site as well as its location and surroundings. Currently, the subject property is only accessible from two sides ofthe subject property, from Woodlawn Avenue and 0 Street. Due to proximity to the San Diego Trolley line/Interstate 5 freeway to the west, and existing development to the north, it would not be feasible to construct either public or private streets along these boundaries. Such limited access may pose some unique and significant challenges as far as routine ingress and egress, emergency access and general traffic circulation. Additionally, this could result in the bulk of housing having to be located within the eastern and southern portions ofthe site. The P modifier would allow tlexibility in the future to make modifications to development standards such as building setbacks in order to accommodate future on-site development proposals. Because no actual development is planned in conjunction with this rezone request, no actual precise plan guidelines are being requested at this time. 4-76 Ordinance No. Page 3 2 THE PROPERTY OR AREA TO WHICH THE P MODIFYING- DISTRICT IS APPLIED IS IN AN AREA ADJACENT AND CONTIGUOUS TO A ZONE ALLOWING DIFFERENT LAND USES, AND THE DEVELOPMENT OF A PRECISE PLAN WILL ALLOW THE AREA SO DESIGNATED TO COEXIST BETWEEN LAND USAGES WHICH MIGHT OTHERWISE PROVE INCOMPATIBLE. The proposed P-modifier will allow future devclopment of the site to achieve greater compatibility with the existing surrounding land uses. Directly north ofthe project site, the land which is zoned R-3 ("Apartment Residential Zone") is developed primarily with apartments and other multi-family structures. To the east, although also designated R-3, contains a mixture ofboth single and multi-family development. To the south ofthe project site, the land, which is zoned MHP (Exclusive Mobilehome Park), is fully developed as an 85 unit mobilehome park. To the west of the project site, the land contains certain road improvements serving Interstate 5 and the right of way for the San Diego Trolley line. In light of the diversity of existing land uses surrounding the project site, statlbelieves that the application of the P-modifier to the project site will allow greater design control over the eventual development of the project sitc to insure compatiblity with the existing uses surrounding the project site. Due to the proximity ofInterstate 5 to the west of the project site and associated noise and air quality concerns, it may be beneficial to design a future project in such away that it is primarily oriented away from the freeway. 3. THE BASIC OR UNDERLYING ZONE REGULATIONS DO NOT ALLOW TI-IE PROPERTY OWNER AND/OR THE CITY APPROPRIATE CONTROL OR FLEXIBILITY NEEDED TO ACHIEVE AN EFFICIENT AND PROPER RELATIONSHIP AMONG THE USES ALLOWED IN THE ADJACENT ZONES. The existing development standards under the R-3 ("Apartment Residential Zone") may be insufficient with respect to providing the City with the "appropriate control orflexibility needed to achieve an efficient and proper relationship among the uses allowed in the adjacent zones. " Application of a Precise Plan Modifying District can provide flexibility in setback requirements. This would allow for a development to achieve a greater separation from the Interstate 5 freeway to the west without reducing the overall amount of density which may be achieved. In this regard, it would help achieve the Chula Vista General Plan goal of providing higher density residential development in proximity to existing transit facilities. Specifically, policy LUT 1.8 is to pursue higher density residential categories that are not' being met within the City. In addition, it would allow for additional design restrictions which will result in a better site design and layout. 4-77 Ordinance No. Page 4 II. ACTION This Ordinance hereby amends the Zoning Map, re-zoning the 4.35 acre Project site located at 701 D Street from MHP (Exclusive Mobilehome Park) Zone to the R-3-P (Apartment Residential, Precise Plan) zone, and establishes a Precise Plan Modifying District based on the tindings that it is consistent with the City of Chula Vista General Plan, and all other applicable Plans, and that the public necessity, convenience, general welfare and good planning and zoning practice support their approval and implementation. III. EFFECTIVE DATE This Ordinance shall take effect and be in full force on the thirtieth day from and after its adoption. Presented by Gary Halbert, PE, AICP Assistant City Manager! Development Services Director 4-78 ..~