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HomeMy WebLinkAboutRRC-03RESOLUTION NO. RRC-3 A RESOLUTION OF THE PALM DESERT RENT REVIEW COMMISSION APPROVING THE STIPULATED AGREEMENT AND ORDER OF THE RENT REVIEW COMMISSION REGARDING INDIAN SPRINGS MOBILE HOME PARK WHEREAS, on February 18, 2009, the Palm Desert Rent Review Commission ("Commission") considered and approved, by unanimous vote and subject to the modifications and conditions described below, the Stipulated Agreement and Order of the Rent Review Commission ("Order") proposed by the Indian Springs Mobile Home Park ("Park") and the Indian Springs Mobile Home Owners Association ("Association") and consented to by 89% of the residents of the Park ("Residents") to resolve the issues between the Park and the Residents that are delineated in the Order; and WHEREAS, approval of the Order was conditioned on: (1) revision of the proposed Order to conform to changes agreed to by the Parties and read into the record of the hearing by Judge Taylor; and (2) execution by the Park, Association, and City of Palm Desert of Three Related Settlement Agreements prior to the close of business on February 27, 2009; and WHEREAS, the specified revisions have been made and agreed to by the Parties and are incorporated into the final Order attached to this Resolution; and the Three Related Settlement Agreements have been executed and submitted to the City prior to the close of business on February 27, 2009; NOW, THEREFORE, IT IS RESOLVED by the Rent Review Commission of the City of Palm Desert, California as follows: That the Stipulation attached hereto is approved as the Final and Binding Order of the Rent Review Commission as to all matters set forth in the Stipulation. PASSED, APPROVED, AND ADOPTED this 18th day of February, 2009, by the Rent Review Board of the City of Palm Desert, California, by the following vote, to wit: AYES: ADAMS, KOFFLER, TORSNEY, WERCHICK NOES: NONE ABSENT: NONE ABSTAIN: NONE illiam Adams, Cit an Rent Review Comi'ni ion ATTEST: Frankie Riddle, Secretary Rent Review Commission APPROVED AS TO FORM: David J. Erwip!City Attorney RMPUB\RHARGREAvEs\305629.1 [This page has intentionally been left blank.] RESOLUTION NO. RCC-3 1 2 3 4 5: 6 7 8 9 10 IN RE: 11 12 13 14 15 16 17 18 19 BEFORE THE PALM DESERT RENT REVIEW COMMISSION INDIAN SPRINGS MOBILEHOME PARK STIPULATED AGREEMENT AND ) ORDER OF THE RENT REVIEW COMMISSION I. Introduction and Purpose. This matter involves the Residents of Indian Springs Mobilehome Park (Residents) and their Homeowners' Association (Association), and IS Palm Desert, LP, a California limited partnership (formerly known as Indian Springs LTD.), the owner of Indian Springs Mobilehome Park (Park Owner). This Stipulation and Agreement resolve Park Owner's two Capital 20 Improvement rent increase applications; Park Owner's Hardship rent increase application; Park 21 Owner's Petition for Legal Interpretations of the City's Rent Control Ordinance and the issues 22 therein; Residents' Petitions for Legal Interpretations of the City's Rent Control Ordinance and the 23 issues therein; and the Residents' challenge to Park Owner's August 1, 2008 rent increase and the 24 issues raised therein and all briefs submitted in support of same, as follows: 25 1. Park Owner's Capital Improvement Rent Increase Application ($329.57) dated 6/07/06 26 2. Resident's Request for Petition for Interpretation of the City of Palm Desert's Mobile Home Park Rent Review Ordinance Chapter 9.50 and Related Guidelines dated 27 08/14/06 28 1// 01053/0001/65116.08 RESOLUTION NO. RRC-3 8I 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 3. Resident's Amendment to Request for Petition for Interpretation of the City of Palm Desert's Mobile Home Park Rent Review Ordinance Chapter 9.50 and Related 2 Guidelines datedl/18/07 3 4. Park Owner's Capital Improvement Rent Increase Application ($86.05) dated 03/31/08 4 5. Residents' Petition for Further Interpretation of Chapter 9.50 of the Palm Desert Municipal Code dated 04/10/08 6. Park Owner's Petition for Interpretation of Chapter 9.50 of the Palm Desert Municipal 6 Code dated 05/09/08 5 7 7. Residents' Formal Objections and Request for Further Clarification to City Attorney Opinion and Recommendation dated 08/07/08 8. Park Owner's Hardship Rent Increase Application ($314.44) dated 09/29/08 The purpose of this Stipulation, Agreement and Order is to resolve these matters without the necessity of further administrative or judicial proceedings and to resolve issues touching the conversion of the Park to resident ownership for all spaces except those seventeen listed in Section IV(A)4 below. II. Factual and Procedural Summary. A. The Park's Base Rents and Base CPI/Residents' Overcharge Claims Indian Springs Mobilehome Park (Park) is located in the City of Palm Desert (City). The Park has 191 total spaces for mobilehomes. Rent increases in the Park for rent controlled spaces are governed by Chapter 9.50 of the City's Municipal Code titled Mobile Home Park Rent Review (the Ordinance). The City first adopted mobilehome rent control on June 23"I, 1983 by Ordinance 329. Over the years the City has amended the mobilehome rent control ordinances on several occasions including repealing and adopting several provisions. These repeals and amendments include repealing and amending the formulae for annual cost of living increases. Over the years, the Park Owner had also petitioned under the provisions of the Ordinance for and obtained from the Rent Review Commission several "hardship" and "capital improvement" rent increases in excess of the automatic annual cost of living increases provided in the Ordinance. The Park's last completed hardship rent increase was filed in 1987 and became effective in 1988. 28 /// -2- 01053/0001/65116.08 RESOLUTION NO. RRC-3 1 A series of disputes have arisen between the Park Owner and the Residents over the 2 appropriate base rents before and after the 1988 hardship rent increase -- including the Park's 1989 3 rents and thereafter. These disputes involve the base rents, subsequent costs of living increases, 4 capital improvement rent increases, and the appropriate Consumer Price Index base month to use in 5 the City's present formula addressing future ongoing calculations of Park rents, and interpretation 6 of all these issues under the various versions of the Ordinance. The Residents submitted a Request 7 for Legal Interpretation on August 14, 2006 and amended its Petition on January 18, 2007. In 8 response, the City Attorney issued an Opinion dated October 9, 2006 which failed to resolve the 9 parties' disputes. The Residents and the Park Owner both submitted Petitions for Legal 10 11 12 13 14 15 16 17 18 19 20 21 Interpretation, as well as various briefs in support thereof. These issues are but some of all of the issues resolved in this stipulated Agreement which issues are more particularly spelled out in the various petitions for interpretation filed by the Residents and the Park Owner and petitions for rent increase filed by the Park Owner with the City. These issues and disputes came to a head when, on or around April 25, 2008, the Park Owner distributed a rent increase Notice (Notice) to the Residents. The Notice is dated April 25, 2008. The Notice informed the Residents of a rent increase scheduled to take effect on August 1, 2008. The Notice described its reasons for raising the rent under the Ordinance and included a cost of living CPI adjustment. The Park Owner mailed the Notice to the Residents as required by the Ordinance. After receiving the Notice, the Residents filed objections with the Rent Review Commission as to the legitimacy of the rents reflected in the rent increase notice. On July 23, 2008, the City Attorney released an Opinion (Opinion) on Park rents and 22 thereafter, the Park Owner issued rent statements to the Residents which reflected a lower CPI rent 23 increase in an attempt to comply with the City Attorney's Opinion. The Residents continued in 24 their objections before the Commission as to both the noticed rents and statement rents. On August 25 7, 2008, the Residents filed formal objections and a request for further interpretation of the July 23, 26 2008 City Attorney Opinion. At the request of the Board, the Residents and the Park Owner both 27 submitted further briefs in support of the Petitions for Legal Interpretation. 28 /// -3- 01053/0001/65116.08 RESOLUTION NO. RRC-3 1 While the Residents objections and requests for interpretations were before the Rent 2 Review Commission, the rents reflected in the Park Owner's rent statements took effect on August 3 1, 2008. All of these above stated rent issues, including the rents as of August 1, 2008, are 4 presently before the Rent Review Commission for its action. 5 On September 18, 2008, the City Attorney released a Clarification of the July 23, 2008 City 6 Attorney opinion (Clarification). The Opinion and Clarification specifically declined to address 7 pre-1996 versions of the Ordinance and all issues related to it. 8 B. Park Owner's $314.44 Hardship Rent Increase Application 9 i On September 29, 2008, the Park Owner filed with the City a petition for a hardship rent 10 increase of $314.44. A rent increase notice was issued by the Park Owner to the Residents 11 12 13 14 15 16 17 effective January 1, 2009. The hardship rent increase application was based upon the City and Rent Commission's maintenance of net operating income formula and was partly to demonstrate to the Commission and the Residents that the Park Owner has not been overcharging Residents for rents. The Park Owner's petition for a $314.44 rent increase is presently before the Rent Review Board for its action. C. Park Owner's $329.57 Capital Improvement Rent Increase Application On June 7, 2006, the Park Owner submitted a Capital Improvement Rent Increase 18 Application seeking a monthly rent increase of $329.57. On July 10, 2007, the Rent Review 19 Commission denied the application for a capital improvement rent increase. Within ten days of the 20 decision, the Park Owner requested the City prepare the administrative record for the $329.57 Rent 21 Increase application. It has been the intent of the Park Owner to seek court review of the Rent 22 Review Commission's decision under Code of Civil Procedure Section 1094.5. That matter is 23 presently pending the City's production of the Administrative Record. The Parties had agreed to 24 stay the production of the Administrative Record pending the outcome of these proceedings. 25 D. Park Owner's $86.05 Capital Improvement Rent Increase Application 26 On March 31, 2008, the Park Owner submitted a Capital Improvement Rent Increase 27 Application seeking a monthly rent increase of $86.05 per space. On September 22, 2008, the Rent 28 Review Commission denied the application for a capital improvement rent increase. Within ten -4- 01053/0001165116.08 RESOLUTION NO. RRC-3 1 days of the decision, the Park Owner requested the City prepare the Administrative Record on the 2 $86.05 Rent Increase application. It has been the intent of the Park Owner to seek court review of 3 the Rent Review Commission's decision under Code of Civil Procedure Section 1094.5. That 4 matter is presently pending adoption by the Rent Review Commission of a final order. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 III. Governing Law. The Ordinance authorizes stipulated agreements. Ordinance Section 9.50.080 entitled "Agreements" allows for the settlement of disputes involving rents. It provides: "Nothing in this chapter shall operate to restrict the right of tenants and management to enter into agreements providing for a fixed term and/or a fixed rent for mobile home tenancies. Such an agreement may be entered into by an individual tenant and management. Such agreement shall apply to all the spaces in a mobile home park provided that four -fifths of the occupied spaces consent to such agreement. The parties to the agreement shall provide the city with satisfactory proof of consent. If the tenants are represented by an association, then if otherwise permitted by law, a majority of the association's board of directors, or similar governing body, may enter into such agreement with the consent of four -fifths of the occupied spaces. (Ord. 560 § 2, 1988: Ord. 456 § 2 (part), 1986)" The Residents' Homeowners Association has polled the Residents of Indian Springs Mobilehome Park and 89% of the Residents have consented to the following terms of this Stipulation and Agreement. Notwithstanding Ordinance Section 9.50.080 and the stipulated agreement and settlement between the Residents and the Park Owner, all seventeen spaces listed in section IV(A)4 below are excluded from these findings and these Space Tenants and the Park Owner reserve all rights and remedies under the law to pursue all issues raised in the various petitions before the City with the exception that all claims raised in the $329.57 and $86.05 Capital Improvements Applications and the sewer component of the $314.44 Hardship Application are expressly waived by the Park Owner and the Park Owner agrees not to challenge the City's $329.57 and $86.05 decisions in any forum. 24 IV. Terms of Agreement. The Terms of this Stipulation and Agreement are as follows: 25 A) Base Date Rents, Base Date CPI and Base Year. 26 Subject to the specific reservations of the Parties as outlined above in Section III involving 27 the seventeen spaces in Section IV(A)4, the Parties agree to the following: 28 01053/0001/65116.08 -5- RESOLUTION NO. RRC-3 1 1) That the base rent going forward for all spaces are the rents as of August 1, 2008 and 2 the base CPI is March 2008 and the base year is 2008. Owner will not take another CPI 3 rent increase unless conversion of the park has not occurred by November 1, 2009, in 4 which case he is entitled to take a CPI increase on November 1, 2009. Such CPI 5 increase will use the August 1, 2008 base rents, the CPI-W of March 2008 base CPI, 6 and the July 2009 CPI (or, the most recent CPI available at the time of the required 7 ; notice) and is subject to all notice periods and requirements and other provisions of the 8 Ordinance. Owner also understands that if the conversion has not occurred by then, the 9 next CPI increase he will be entitled to will be November 1, 2010 and that from 10 November 1, 2009 forward, if the conversion does not occur, annual CPI increase will 11 be November 1, of each year or later. 12 2) That the base rents prior to August 1, 2008 and the base CPI prior to March 2008 are 13 now moot in light of settlement of the base rent and base CPI. All petitions by Park 14 Owner and Residents for interpretation and/or clarification are withdrawn by both Park 15 Owner and Residents except as for issues as outlined above in Section III related to the 16 ' rights of the Parties concerning spaces identified in section IV(A)4 below. 17 3) Residents withdraw their rent overcharge claims, relinquish such claims, and agree 18 never to file such claims again in any forum except as for issues related to the rights of 19 the Parties concerning spaces identified in section IV(A)4 below unless the Park 20 conversion does not occur by September 30, 2010, in which case the Association and 21 Residents reserve all their rights under the Ordinance to pursue any new or other claims 22 not raised in their previous petitions as enumerated in Section I. 23 4) With respect to spaces 25, 37, 43, 46, 47, 72, 84, 85, 86, 103, 111, 112, 117, 125, 137, 24 139 and 142 (which were once on long term leases) no rights are waived by these Space 25 Tenants and the Park Owner (with the exception that all claims raised in the $329.57 26 and $86.05 Capital Improvements Applications and the sewer component of the 27 $314.44 Hardship/Fair Return Application are expressly waived by the Park Owner and 28 the Park Owner agrees not to challenge the City's $329.57 and $86.05 decisions in any -6- 01053/0001/65116.08 RESOLUTION NO. RRC-3 1 2 3 4 5 6 7 8 91 10 11 12 13 14 15 16 17 18 forum. The issues of legal interpretations and rent overcharge and roll back of rents and allowable rent increases are reserved and not a part of this agreement. As to these seventeen spaces, the Tenants of these spaces and the Park Owner have elected to proceed under the Ordinance. Notwithstanding Ordinance Section 9.50.080 and the stipulated agreement and settlement between the Residents' and the Park Owner, all seventeen spaces listed above are excluded from these findings and these Space Tenants and the Park Owner reserve all rights under the law to pursue all issues raised in the various petitions before the Board and any other remedy available to them (again, with the exception that all claims raised in the $329.57 and $86.05 Capital Improvements Applications and the sewer component of the $314.44 Hardship/Fair Return Applications are expressly waived by the Park Owner and the Park Owner agrees not to challenge the City's $329.57 and $86.05 decisions in any forum). It is possible that a settlement may be reached for these spaces also, but it is not necessary that these be settled to fully effectuate the present settlement. If it is necessary for that issue to come before the Board, the parties request that such a hearing does not occur for at least 30 days after the February 18, 2009 hearing on these findings. B) Park Owner's $329.57 Capital Improvement Rent Increase Application. 19 Park Owner withdraws its $329.57 Capital Improvement rent increase Application and will 20 not challenge the decision of the Rent Review Commission related to this Capital Improvement. 21 Park Owner will not file another Capital Improvement Application unless the Park conversion does 22 not occur by September 30, 2010, in which case the Park Owner reserves its rights under the 23 Ordinance to file new Capital Improvement Rent Increase Applications unrelated to claims raised 24 in the $329.57 and $86.05 sewer Capital Improvements Applications and the sewer component of 25 the $314.44 Hardship Application. 26 Park Owner also reserves the right to file new Capital Improvement Applications, pursuant 27 to the City's Rent Control Guidelines, section 101(c), occurring before Conversion of the Park 28 under the following circumstances: -7- 01053/0001/65116.08 RESOLUTION NO. RRC-3 1 1) Two-thirds of the tenant approve a "new improvement"; 2 2) Majority of tenants approve a "capital improvements to modernize upgrade or refurbish 3 already existing improvements"; or 4 3) An "involuntary improvement" is required by a governmental entity or by an act of God 5 , or a natural disaster. The Park Owner and his representatives represent that they are not aware of 6 any requirements by any state, federal or local governmental entity of an "involuntary 7 improvement." If a Capital Improvement Application is filed by the Park Owner under this section 8 9 10 11 12 13 14 15 16 17 18 19 and the Residents and or Association present evidence that the Owner and/or his representatives (including his legal counsel) had knowledge of this requirement on or before the execution of this Order by the Rent Review Commission, that can alone be grounds for denial of such Capital Improvement Application. C) Park Owner's $86.05 Capital Improvement Application. Park Owner withdraws its $86.05 Capital Improvement rent increase Application and will not challenge the decision of the Rent Review Commission related to this Capital Improvement. Park Owner will not file another Capital Improvement Application unless the Park conversion does not occur by September 30, 2010, in which case the Park Owner reserves its rights under the Ordinance to file new Capital Improvement Rent Increase Applications unrelated to claims raised in the $329.57 and $86.05 sewer Capital Improvements Applications and the sewer component of the $314.44 Hardship Application. 20 Park Owner also reserves the right to file new Capital Improvement Applications, pursuant 21 to the City's Rent Control Guidelines, section 101(c), occurring before Conversion of the Park 22 ; under the following circumstances: 23 1) Two-thirds of the tenant approve a "new improvement"; 24 2) Majority of tenants approve a "capital improvements to modernize upgrade or refurbish 25 already existing improvements"; or 26 3) An "involuntary improvement" is required by a governmental entity or by an act of God 27 or a natural disaster. The Park Owner and his representatives represent that they are not aware of 28 any requirements by any state, federal or local governmental entity of an "involuntary -8- 01053/0001/65116.08 RESOLUTION NO. RRC-3 1 improvement." If a Capital Improvement Application is filed by the Park Owner under this section 2 and the Residents and or Association present evidence that the Owner and/or his representatives 3 (including his legal counsel) had knowledge of this requirement on or before the execution of this 4 Order by the Rent Review Commission, that can alone be grounds for denial of such Capital 5 • Improvement Application. 6 , D) Park Owner's $314.44 Hardship Rent Increase Application. 7 Park Owner withdraws its $314.44 Hardship Rent Increase Application except as to the 8 seventeen spaces identified in section IV(A)4 and will not file another one with the City unless the 9 10 11 12 13 14 15 16 17 18 19 Park conversion does not occur by September 30, 2010, in which case the park owner reserves its rights under the Ordinance to file new Hardship Rent Increases if necessary. Any future Hardship Rent Increase Application (including any against the seventeen spaces identified in section IV(A)(4) will not include any line item related to the sewer claims in the $329.57 and $86.05 Capital Improvements Applications and the $314.44 Hardship/Fair Return Application. V. Dismissal of All Petitions. The Residents and Park Owner agree that in exchange for this Stipulation and Settlement Agreement being approved and adopted by the Rent Review Commission as a settlement and its Order, the Rent Review Commission shall dismiss all Petitions, requests and objections and not conduct further proceedings in this matter and on all issues presented in filings before the Commission with the exception of those spaces listed in IV(A)4. VI. No 2008 Rent Increase Notice to Residents. The Residents and Park Owner agree that no 20 new notice of 2008 rent increase is required under the terms of this Stipulation and Settlement 21 Agreement. 22 A. Binding Nature of Stipulation. The foregoing, when approved by the Rent Review 23 Commission, shall constitute its final decision pursuant to Section 9.50.070 on all of the Petitions 24 ' presently before the Rent Review Commissions, and a binding Settlement agreement between the 25 Residents and Park Owner under Section 9.50.080 and shall bind all parties to these proceedings as 26 well as all Rent Control Residents of Indian Springs Mobilehome Park regardless of whether or not 27 said parties participated in these proceedings, with the exception of those spaces listed in IV(A)4. 28 The binding effect of this Settlement and Order, as to all such persons, however situated, is based -9- 01053/0001/65116.08 RR3OLUTION NO. RRC-3 1 upon the Rent Review Commissions review of all the documents submitted herein, all 2 documentation and arguments presented to the Rent Review Commission throughout these 3 proceedings, and is intended to act as a final and full determination of all disputes concerning the 4 issues before the Commission with the exception of rights reserved in Section IV(A)4. 5 ; B. Waiver of Appeal Rights. With the exception of the rights reserved in Section 6 IV(A)4, the parties hereto waive any and all rights of appeal from this Decision, Stipulation, 7 8 9 10 11 12 13 14 15 16 17 18 David Erman 19 Agreement and Order, or any right they might have to challenge this Decision, Stipulation, Agreement and Order by Writ of Mandate or otherwise, and this Decision, Stipulation, Agreement and Order is intended as a full and final disposition of claims concerning the issues presented in all the proceedings before the Commission. This Decision, Stipulation, Agreement and Order constitutes a binding and informed waiver of those appeal rights which might otherwise apply pursuant to California Code of Civil Procedure Section 1094.5 and/or pursuant to Sections 9.50.090; 9.50.100; 9.50.140; or any other provisions of the Ordinance. APPROVED AS TO CONTENT AND APPROVED AS TO CONTENT AND FORM: FORM: Attorney for CITY OF PALM DESERT Attorney for INDIAN SPRINGS MOBILEHOME OWNERS' ASSOC. 20 i MOBILEHOME PARK 21 22 David Spangenberg, Esq. 23 Sunny Soltani, Esq. Attorney for INDIAN SPRINGS IS PALM DESERT, LP, 24 a California limited partnership 25 By; Goldstein Properties, Inc., a California corporation 26 Its General Partner 27 By: 28 James Goldstein, President 01053/0001/65116.08 -10- RESOLUTION NO. RRC-3 1 upon the Rent Review Commissions review of all the documents submitted herein, all 2 documentation and arguments presented to the Rent Review Commission throughout these 3 : proceedings, and is intended to act as a final and full determination of all disputes concerning the 4 issues before the Commission with the exception of rights reserved in Section IV(A)4. 5 : B. Waiver of Appeal Rights. With the exception of the rights reserved in Section 6 ' IV(A)4, the parties hereto waive any and all rights of appeal from this Decision, Stipulation, 7 ; Agreement and Order, or any right they might have to challenge this Decision, Stipulation, 8 ' Agreement and Order by Writ of Mandate or otherwise, and this Decision, Stipulation, Agreement 9 • • and Order is intended as a full and final disposition of claims concerning the issues presented in all 10 the proceedings before the Commission. This Decision, Stipulation, Agreement and Order 11 i constitutes a binding and informed waiver of those appeal rights which might otherwise apply 12 13 pursuant to California Code of Civil Procedure Section 1094.5 and/or pursuant to Sections 9.50.090; 9.50.100; 9.50.140; or any other provisions of the Ordinance. 14 APPROVED AS TO CONTENT AND FORM: 15 16 . Attorney for CITY OF PALM DESERT 17 18 David Erwiff, Esq. 19 20 MOBILEH 21� 22� D'Spange erg, Esq. 23 24 25 26 27 28 APPROVED AS TO CONTENT AND FORM: Attorney for INDIAN SPRINGS MOBILEHOME OWNERS' ASSOC. Sunny Soltani, Esq. Attorney for INDIAN SPRINGS IS PALM DESERT, LP, a California limited partnership By; Goldstein Properties, Inc., a California corporation Its General Partner By: James Goldstein, President 01053/0001/65116.08 -10- RESOLUTION NO. RRC-3 1 upon the Rent Review Commissions review of all the documents submitted herein, all 2 documentation and arguments presented to the Rent Review Commission throughout these 3 proceedings, and is intended to act as a final and full determination of all disputes concerning the 4 , issues before the Commission with the exception of rights reserved in Section IV(A)4. 5 B. Waiver of Appeal Rights. With the exception of the rights reserved in Section 6 IV(A)4, the parties hereto waive any and all rights of appeal from this Decision, Stipulation, 7 Agreement and Order, or any right they might have to challenge this Decision, Stipulation, 8 Agreement and Order by Writ of Mandate or otherwise, and this Decision, Stipulation, Agreement 9 and Order is intended as a full and final disposition of claims concerning the issues presented in all 10 the proceedings before the Commission. This Decision, Stipulation, Agreement and Order 11 constitutes a binding and informed waiver of those appeal rights which might otherwise apply 12 pursuant to California Code of Civil Procedure Section 1094.5 and/or pursuant to Sections 13 9.50.090; 9.50.100; 9.50.140; or any other provisions of the Ordinance. 14 APPROVED AS TO CONTENT AND FORM: 15 16 Attorney for CITY OF PALM DESERT 17 18 David Erwin, Esq. 19 20 MOBILEHOME PARK 21 22 David Spangenberg, Esq. 23 24 25 26 APPROVED AS TO CONTENT AND FORM: DIAN S RINGS ME ERS' AOC. 1 Attorney for INDIAN SPRINGS IS PALM DESERT, LP, a California limited partnership By; Goldstein Properties, Inc., a California corporation Its General Partner 27 By: 28 James Goldstein, President nincfl inn.,, -10- 02-26-09 06:04pm From- T-815 P.007/010 F-830 RESOLUTION NO. RRC-3 1 upon the Rent Review Commissions review of all the documents submitted herein, all 2 documentation and arguments presented to the Rent Review Commission throughout these 3 proceedings, and is intended to act as a final and full determination of all disputes concerning the 4 issues before the Commission with the exception of rights reserved in Section IV(A)4. 5 B. Waiver of Appeal Rights. With the exception of the rights reserved in Section 6 IV(A)4, the parties hereto waive any and all rights of appeal from this Decision, Stipulation, 7 Agreement and Order, or any right they might have to challenge this Decision, Stipulation, 8 Agreement and Order by Writ of Mandate or otherwise, and this Decision, Stipulation, Agreement 9 10 11 12 13 14 15 16 17 and Order is intended as a full and final disposition of claims concerning the issues presented in ail the proceedings before the Commission. This Decision, Stipulation, Agreement and Order constitutes a binding and informed waiver of those appeal rights which might otherwise apply pursuant to California Code of Civil Procedure Section. 1094.5 and/or pursuant to Sections 9.50.090; 9.50.100; 9.50.140; or any other provisions of the Ordinance. APPROVED AS TO CONTENT AND APPROVED AS TO CONTENT AND FORM: FORM: Attorney for CITY OF PALM DESERT Attorney for INDIAN SPRINGS MOBILEHOME OWNERS' ASSOC. 18 David Erwin, Esq. 19 Sunny Soltani, Esq. 20 Attorney for INDIAN SPRINGS MOBILEHOME PARK 21 22 David Spangenberg, Esq. 23 IS PALM DESERT, LP, 24 a California limited partnership 25 26 By; Goldstein Properties, Inc., a California corporation Its Gene Partner 27 By: awes Goldstein, President 28 -10- RESOLUTION NO. RRC-3 1 2 ORDER APPROVING The parties having so stipulated upon the advice of their respective counsel and good cause 3 appearing therefore, 4 ' IT IS ORDERED that the foregoing terms shall be and are approved as the findings and 5 I decision of the Rent Review Commission. 6 SO ORDERED. 7 , PALM DESERT MOBILE HOME RENT REVIEW BOARD 8 9 Adams, Chairman 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -11- 01053/0001/65116.08