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To: Joel Hanson <br />From: Jerry Bourdon <br />Date: December 28, 2000 <br />Memorandum <br />For settlement discussion only <br />Subject: Final payment for services <br />Settlement offer <br />Introduction <br />The following summarizes our offer to settle the unpaid invoices. <br />In essence this settlement offer: <br />• splits the cost of the Arcade issue, <br />• removes our claim for interest, <br />• discounts the mapping costs, and <br />• provides a discount for a settlement agreement in lieu of litigation <br />In addition to the financial settlement we also expect the following <br />• holdharmless for the utility mapping <br />• the terms of the agreement will be handled discretely and professionally <br />Summary of claim <br />Claimed amount <br />Unpaid invoices 21,562.95 <br />Interest 6,407.19 <br />Unpaid mapping 14,702.13 <br />Total Claimed Amount 42,672.70 <br />Settlement adjustment - deducts <br />Cost split of Arcade 8,458.85 <br />Interest 6,407.19 <br />Mapping write off 3,202.13 <br />Dispute resolution avoidance 6,604.10 <br />Settlement Offer 18,000.00 <br />Comments <br />We reiterate for the record that we believe that BRAA is not responsible for the Arcade issue. We <br />believe that contractor error or interference by others is the more likely cause of the issue. <br />This settlement is a good faith offer to settle our differences. The settlement offer recognizes that <br />there are inherent differences of opinion between our firm and the city that we will never be able <br />to resolve. However litigation is neither in Little Canada's or our firm's best interests. <br />Acceptance of this offer by both parties shall be a release of all claims against the other. <br />Page 84 <br />