2011-02-14 Settlement Agreement Wording r
CO URI, MACARTHUR & R UPPE, P.L.L.P
Attorneys at law
Michael C. Couri* 705 Central Avenue East Sarah E. Schwarzhoff
Andrew J. MacArthur PO Box 369
Robert T. Ruppe ** St. Michael, MN 55376 -0369
(763) 497 -1930
*Also Licensed in Illinois (763) 497 -2599 (FAX)
* *Also Licensed in California www. courimacarthur. com
February 14, 2011
VIA FACSIMILE 763 - 682 -7300
The Honorable Geoffrey W. Tenney
Wright County District Court
10 2 nd Street N.W., Room 201
Buffalo, MN 55313 -1192
Re: City of Albertville v. Alpine Capital, LLC; Court File No. 86- CV -09-
6850.
Dear Judge Tenney:
The above matter is scheduled for a pretrial hearing before the Court on February
15, 2011 at 1:30 p.m. As you may recall, at the last pretrial hearing the parties had been
negotiating a settlement and were working with the banks which are secured creditors of
Alpine Capital. Since our last hearing, the parties have agreed upon the language of the
settlement agreement, and are now waiting for the banks to release their secured position
on selected parcels of real estate that will be transferred to the City as part of the
settlement. The parties anticipate that these releases will be obtained by the end of
February, at which time the executed settlement agreement will be filed with the Court
requesting the Court to dismiss this case.
Given this schedule, both myself and Mike Brutlag, the attorney for the Alpine,
are requesting that the Court cancel the pretrial set for tomorrow afternoon and
reschedule a pretrial for 30 to 60 days out, by which time we expect this case to be fully
settled and dismissed. Both Mr. Brutlag and myself have discussed this issue with your
clerk, Ann Jakala earlier today, and Mr. Brutlag is in agreement with this request. Thank
you for your consideration of this request.
i
The Honorable Geoffrey W. Tenney
February 14, 2011
Page 2 of 2
Sincerely,
Z� ( ;t"
Michael C. Couri
Couri, MacArthur & Ruppe, P.L.L.P.
Cc: Mr. Mike Brutlag