Minneapoils parking lot dispute

7/27/2019 Minneapoils parking lot dispute

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STATE OFMINNESOTACOUNTY OF HENNEPIN

DISTRICT COURTFOURTH JUDICIAL DISTRJCTCASE TYPE: OTHERCIVIL

Minneapolis Venture LLC, Case No.:Judge:Plaintifl, SUMMONS

Minnesota Sports Facilities Authority,Det'endant.

THIS SUMMONS IS DIRECTED TO MINNESOTA SPORTS FACILITIES AUTHORITY.l. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you.The Plaintills Complaint against you is attached to this Summons. Do not throw these papersaway. They are otficial papers that afTect your rights. You must respond to this lawsuit eventhough it may no1 yet be filed with the Court and there may be no court file number on thisSummons.2. YOU MUST REPLY WITHIN 20 DAYS TO PROTECT YOUR RIGHTS. Youmust give or mail to the person who signed this summons a written response called an Answerwithin 20 days of the date on which you received this Summons. You must send a copy of your

Answer to the person who signed this Summons located at:Anthony Ostlund Baer & Louwagie P.A.3600 Wells Fargo Center90 South Seventh StreetMinneapolis. MN 554023. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written responseto the Plaintiff s Complaint. In your Answer you must state whether you agree or disagree witheach paragraph ol the Complaint. If you believe the Plaintiff should not be given everythingasked for in the Complaint, you must say so in your Answer.4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTENRESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THISSUMMONS. If you do not answer within 20 days, you will lose this case. You will not get totell your side of the story, and the Court may decide against you and award the Plaintiffeverything asked lbr in the Complaint. If you do not want to contest the claims stated in theComplaint, you do not need to respond. A defautt judgment can then be entered against you forthe relief requested in the Complaint.

CIV-2OO I Rev: 6/2010


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5. LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. If you donot have a lawyer. the Court Administrator may have information about places where you canget legal assistance. Even if you cannot get legal help, you must still provide a writtenAnswer to protect your rights or you may lose the case.6. ALTERNATM DISPUTE RESOLUTION. The parties may agree to or beordered to participate in an altemative dispute resolution process under Rule I 14 of theMinnesota General Rules of Practice. You must still send your written response to the Complainteven if you expect to use altemative means of resolving this dispute.

ANTHONY OSTLUND BAER &LOUWAGIE P.ADated: August 13. 2013

90 South Seventh Street, Suite 3600Minneapolis, MN 55402Telephone: 612-349-6969ATTORNEYS FOR PLAINTIFF

By,atr (#0163715)Philip -f.-Kdplan (#038935 1 )

CIV-2OO I Rev:6/2010


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STATE OF MINNESOTACOUNTY OF HENNEPIN

DISTRICT COURTFOURTH JUDICIAL DISTRICTCASETYPE: OTHERCIVI

Minneapolis Venture LLC, Case No.:Judge:Plaintift COMPLAINTMinnesota Sports Facilities Authority,

Defendant.

PlaintifT Minneapolis Venture LLC, as and lbr its Complaint against DefendantMinnesota Sports Facility Authority, states and alleges as fbllows:

I . Minneapolis Venture LLC (''Minneapolis Venture") is a Minnesota limitedliability company with a principal place of business at 800 Nicollet Mall, Suite 2850,Minneapolis, Minnesota. Minneapolis Venture is the fee owner of real property located at701 South Fourth Street in Minneapolis known as the Downtown East Parking Ramp Property("Downtown East"). Minneapolis Venture acquired Downtown East from its prior owner, theCity of Minneapolis, in late 2007.

2. The Minnesota Sports Facility Authority (the "MSFA") is a public body,corporate and politic, and political subdivision of the srate created pursuant to Minn. Stat.$ 473J.07. The MSFA's principal place of business is located at 900 South Fifth Street,Minneapolis, Minnesota.3. Downtown East is included in the delinition ofthe Stadium Site as set forth inMinn. Stat. Ch.473J, which became e1'fective on May 15, 2012.


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4. On February 1, 2013, Ted Mondale ("Mondate"), in his capacity asCEO/Executive Director of the MSFA, notified Minneapolis Venture of the MSFA's interest inacquiring Downtown East, and took the initial steps required fbr an eminent domain proceedingunder Minn. Stat. { I17.036. A true and correct copy of Mondale's letter is attached hereto asExhibit A and incorporated herein by ret'erence.

5. On May 30, 20'13, as discussions about a possible acquisition of Downtown Eastby the MSFA continued, Mondale again wrote to Minneapolis Venture. In the May 30 letter, theMSFA claimed that Minneapolis Venture was obligated to extend the term of a Use Agreementand Right of [:ntry dated September 17 ,2003 (the "Use Agreement") beyond the terminationdate expressly stated in the Use Agreement. A true and correct copy of Mondale's letter isattached hereto as Exhibil B and incorporated herein by reference.

6. 'fhe Use Agreement is a written agreement originally between the MinneapolisCommunity Development Agency ("MCDA"), as the then-owner of Downtown East, and theMetropolitan Sports Facilities Commission (the "Commission"), as the owner of the Metrodome.The Use Agreement permitted the Commission to "hold Metrodome related events, from time totime. on the Premises, subject to the terms and conditions of this Agreement." A true and correctcopy ofthe Use Agreement is attached hereto as Exhibit C and incorporated herein by reference.

7. Pursuant to Section 2 of the Use Agreement, the Commission's right to useDowntown East lbr approved Metrodome events will end as of "October 3 l, 2013, after whichtime the right of the Commission to use the Concession Facilities and schedule and holdMetrodome Events on the Premises shall terminate."


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8. The MCDA and the Commission agreed to "negotiate in good faith the right toextend" the Use Agreement "so long as the Metrodome continues to be operated as a sportsarena."

9. ln response to Mondale's May 30,2013 letter, Minneapolis Venture informed theMSFA that the Use Agreement would, according to its express terms, terminate on October 31,2013. Minneapolis Venture offered to consider any proposal that the MSFA may choose tomake for a new use agreement. To date, the MSFA has not made any proposal for extending itsuse of Downtown East beyond October 3l .

10. At a meeting between representatives of Minneapolis Venture, the MSFA and theMinnesota Vikings Footbalt Club, LLC ("Vikings") on April 18, 201 3, the Vikings and theMSFA said they were considering whether Downtown East would be needed for the newstadium development, and that Minneapolis Venture would be informed of the decision within30 days. 'l'hat deadline was missed. The promise to make a decision "soon" was repeated onnumerous occasions over the fbllowing months, including at another lace-to-face meetingbetween Minneapolis Venture, the MSFA and the Vikings on June 19,2013.

I l. Throughout the spring and summer of 2013, while the MSFA was tellingMinneapolis Venture that it did not krow whether it wanted to acquire Downtown East, theMSFA was communicating to the public that Downtown East was within its control. Thiscommunication was accomplished by images and renderings, including those displayed at thenew stadium design unveiling on May I 3, 201 3, that depict Downtown East as a part of thestadium site. True and correct copies of some ofthose published images are attached hereto asExhibit D.


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12. On JuI1 29,2013, the MSFA issued its Final Environmental Impact Statement("EIS"). The EIS includes many references to Downtown East as a part ofthe stadium project.The EIS presents two altemative plaza configurarions both of which include Downtown East.The EIS also includes two altemative reserve parking plans both of which include DowntownEast. Throughout the EIS, Downtown East is treated as an integral part ofthe stadiumdevelopment, not as the private property owned by Minneapolis Venture.

13. In addition, upon infbrmation and belief, the negotiations and discussions betweenthe MSFA, Ryan Companies and the City of Minneapolis regarding a proposed mixed-usedevelopment and adjacent park have included negotiations over the right to operate and receiverevenues tiom the Downtown East parking ramp owned by Minneapolis Venture. Thesediscussions and negotiations proceeded as if Downtown East were owned by the MSFA.

14. Alier the MSFA repeatedly told Minneapolis Venture that it would make adecision with respect to Downtown East no later than July 31, another meeting took place onAugust 6, 2013. At that meeting, Michelle Kelm Helgen, the Chair of the MSFA, toldMinneapolis Venture that a determination would be made no later than Friday, August 9.

I 5. On Friday, August 9, 2013, Minneapolis Venture received a letter from TedMondale as the CE0/Executive Director of the MSFA. In that letter, the MSFA once againlailed to state whether it is going to acquire the property belonging to Minneapolis Venture,stating instead that MSFA "is considering whether to acquire" Downtown East.

16. On Monday, August 12,2013, Minneapolis Venture gave the MSFA formalnotice ofthe termination oi the Use Agreement as ofOctober 31,2013. A true and correct copyof the termination notice provided to the MSFA is attached hereto as Exhibit E and incorporatedherein by retbrence.


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COUNT ONEDECLARATORY JUDGMENTMinn. Stat. Ch.55517. Minneapolis Venture restates all ofthe allegations of paragraphs I through l6

above as though lully set tbrth herein.18. Minneapolis Venture and the MSFA have a genuine and present controversy

about their respective rights and obligations under the Use Agreement, the parties have takenadverse positions on the issue, and the Court is capable of granting reliefin the lorm ofadeclaratory judgment pursuant to Minn. Stat. Ch. 555.

19. Minneapolis Venture and the MSFA have a genuine and present controversyabout communications to the public by which the MSFA implies that it owns or controlsDowntown East, the parties have taken adverse positions on the issue, and the Court is capable ofgranting specific reliefin the form ofa declaratory judgment pursuant to Minn. Stat. Ch. 555.

20. Minneapolis Venture is entitled to a declaration of the Court that:a. The MSF'A is not a party to and has no rights under the Use Agreement;b. 'to the extent, if any, that the MSFA may be deemed a permitted assignee of theCommission under the Use Agreement, the MSFA's rights are strictly limited tothose rights expressly stated in the Use Agreement;c. To the extent, if any, that the MSFA may be deemed a permitted assignee of theCommission under the Use Agreement, all of the MSFA's rights under the UseAgreement shall terminate on October 31,2013;d. The MSFA does not have any right, pursuant to the Use Agreement or any otherauthority, to possess, control or own Downto\rrl East;e. The MSFA does not have any right to represent, implicitly or explicitly, that itpossesses, controls or owns Downtown East; andl'. Ihe MSFA must immediately stop and refrain from representing, implicitly orexplicitly, that it possesses, controls or owns Downtown East.


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WHEREFORE, Plaintiff Minneapolis Venture LLC demands judgment in its favor andagainst the MSF'A as follows:

t. Declaring that:The MSFA is not a party to and has no rights under the Use Agreement;To the extent, if any, that the MSFA may be deemed a permitted assignee of theCommission under the Use Agreement, the MSFA's rights are strictly limited tothose rights expressly stated in the Use Agreement;To the extent, if any, that the MSFA may be deemed a permitted assignee of theCommission under the Use Agreement, all of the MSFA's rights under the UseAgreement shall terminate on Ocrober 31,2013;The MSFA does not have any right, pursuant to the Use Agreement or otherauthority, to possess, control or own Downtown East;The MSFA does not have any right to represent, implicitly or explicitly, that itpossesses, controls or owns Downtown East; andThe MSFA must immediately stop and refrain from representing, implicitly orexplicitly, that it possesses, controls or owns Downtown East;Awarding Minneapolis Venture its attomeys' fees, costs and disbursements

d.

c.

2.incurred herein to rhe greatest extent allowed by law; and

3. Granting such other and lurther relief as the Court may deem just and equitable.ANTHONY OSTLUND BAtrR &LOUWAGIE P.A.

Dated: August 13.2013

Philip J. Kaplan (#0389351)[email protected] South Seventh Street, Suite 3600Minneapolis, MN 55402Telephone: 612-349-6969ATTORNEYS FOR PLAINTIFF

6

a.b.

e.

Norman (Ba\r (#016371 5)nbaer(@aoblE-w.com


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ACKNOWLEDGEMENTThe undersigned hereby acknowledges that costs, disbursements and reasonable attomey

and witness f'ees may be awarded pursuant to Minn. Stat. $ 549.21l, to the parties against whomthe allegations in the Summons and Complaint are asserted.

By:


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Minnesota Sports Facilities Authority900 South sth Street, Minneapolis, MN 55415

February 1, 2013Robert LuxMinneapolis Venture LLC800 Nicollet Mall, Suite 2850Minneapolis, MN 55488

Acquisition of Downtown East Parking Ramp Property by Negotiation or EminentDomainDear Mr. Lux:

As you know, the Minnesota Sports Facilities Authority (the "Authority") is interestedin acquiring from Minneapolis Venture LLC ("Minneapolis Venture") the property known as theDowntown East Parking Ramp Property ("Downtown East"), a parcel located at 701 4s StreetSouth in Minneapolis, in connection with the construction of a new stadium on the site currentlyoccupied by the Metrodome.Pursuant to Minn. Statute $ 117.036, the Authority is hereby transrnifting to you itsappraisal of Downtown East. Please note that, as provided in Minn. Stat. $117.036 (Subd. 2),the appraisers, Darren Bowen and Todd Reid, did confer with representatives of the Ownerconceming the property.Also pursuant to Minn. Stat. $ 117.036, the Authority hereby informs you of yourright to obtain your own appraisal of the property, subj ect to the provisions of that statute.Minneapolis Venture is entitled by statute to reimbursement of its reasonable costs incurred inobtaining its own appraisal (up to a rnaximum of $5,000.00).For a period ofnot less than 60 days, beginning today, the Authority is ready andwilling to negotiate with Minneapolis Venture for the acquisition of the Downtown Eastproperty. Please note that the Authority contemplates acquiring (by a negotiated transaction orby eminent domain if necessary) a fee simple interest in the Downtown East property, ,:e., thiswill be a "full taking" within the meaning of $ I17.036. In conducting negotiations, theAuthority will consider the enclosed appraisal, any appraisal you choose to provide to theAuthority, and any other relevant information provided by you or otherwise known to theAuthoriry.ln addition, in anticipation of the negotiations, we request that Minneapolis Ventureallow the Authority and its representatives access to the Downtown East property to conduct

Phone: 612-3324386 TTY: 1{00627-3529 Fax: 6'12-3324334 www.msfa.com

Re:

EXHIBIT AAnnrBiivAdron/Eq'ral Opponunily Enployer

MINNESOTAAUTHORITYk


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Minnesota Sports Facilities Authority900 South 5th Skeel, Minneapolis, MN 55415

environmental testing. If this is acceptable, we will be happy to discuss the scheduling andplans for such testing with you.With regard to the negotiations, we are available to meet with representatives ofMinneapolis Venture at a mutually convenient time or to proceed by making a written offer.The Authority is willing to pay the full value shown in the enclosed appraisal, subject todeductions, if any, necessitated by environmental issues. We look forward to hearing from youregarding the best way to proceed with the negotiations.

Executive Director/CEOMinnesota Sports Facilities Authority

Phone:612-332-0386 TTY: 1-80G627-3529 Fax:6'12-332-8334 www.msfa.com Ajlimslive Actiofl /Equai Opportuniy Emproyer

g@rQy yegrf,O/{//'h-"1,/__/TedMond,ale


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Minnesota Sports Facilities Authority90O South sth Street, Minneapolis, MN 55415

Phoner612-332-0366 TTY.1{00{27-3529 Fax 612-332-8334 rvww.msfa.com

EXHIBIT B

May 30, 2013Robert LuxMinneapolis Venture LLC800 Nicollet Mall, Suite 2850Minneapolis, MN 55488

Re: Use A8reement and Ritht of Entry for Stadium PlazaDear Mr. Lux:

The Minnesota Sports Facilities Authority (the "Authorit/,l requests that Alatus extend the UseAgreement and Right of Entry (the "Agreement") for the plaza (the "plaza") located on the property at 701Fourth Srreet South and 424 Kirby Puckett Place, Minneapolis, Minnesota (the "property") subject to the sameterms for a 30-year period as may be extended. Alatus, as the owner of the Property, is subject to the obligationto extend the Agreement because the Agreement runs with the land and was identified as burdening theProperty in Alatus's purchase agreement with the City of Minneapolis. The Agreement was recorded against theProperty by the Memorandum of Use Agreement and Right of Entry dated October 25, 2007. Correspondingly,the Authority is the successor to Metropolitan Sports Facilities Commission's rithts and obligations under theAgreement pursuant to Minnesota statute s 473J.25.As you are aware, the Authority is buildinB a new stadium on the Metrodome site to provide a sportsarena for the Minnesota Vikings and other sportlnt activities. ln conjunction with the new stadium, theAuthority Intends to continue to use the Plaza as provided for in the Agreement. The Plaza was built with state

and federal funds to serve the Hiawatha Line's Downtown EasVMetrodome Station during sporting events atthe Metrodome site. The purpose and intent of the Agreement is that the Plaza will continue to serve these usesso long as the Metrodome site is used as a sportin8 arena. Specifically, section 2 of the Agreement provides"[Alatus] and the [Authority] agree to negotiate in good faith the right to extend this Agreement to use the[Plaza] so long as the Metrodome continues to be operated as a sports arena." Because the new stadium willoccupy the same location and serve the same sports arena function as the Metrodome, the Authority is entitledto extend its use of the Plaza under the Agreement. Accordintly, the Authority expects Alatus will honor itsobligations to extend the Agreement subiect to the same or similar terms as the Plaza is now used by theAuthority.

Please contact me to discuss the extension of the Use Agreement and Right of Entry.Sincerely,/)140,tL_/eultea vondateCEO/Executive Director

Alrinnauv. A6|on/Equ6t Oppo(lunity Emproyr

lti|.|5:9ii.AI.'THOPITYk


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USE AGR,EETiENTAND

RIOHT OF ENTRY(Oowntown East LRT Stte Publlc plara . ,Uletrodome Related Events)TH,s AGREEMEM, rflado as of Sptambor 17,2003 by and betwEen the MinneapolieCommunlty Devolopmont Agency, a pub[c body corporate and politic under he lar,vs ofMinnesota (herelnafter 'MCDA"), and he Metsopolltan Sports Facltlfas Commlsslon, apoliIcal subdMsion of tho Stale ol MinneEota organized pursuant to Minnesola Statutes,Sectton 473 551 eL seq (hereinafter'Commisston').WHEREAS, the MCDA is ths feo ol/nor of cortaln real prop{ty located on the blockbetween Park Av6nue South, Fourth StrBet Souh, Klrby puc*ett place and Frfth S:Eeet Salth,known as 701 Founh Steet South and 424 Kitby Pud(ett Plce, Mlnn6apolls, Mlnne8ote(herelnefier "MCDA Property'); andWHEREAS, the Commisslon b the ovinBr and oparElor of the Hubert H HumphreyMetrodome Sports Cenler (lhe 'Metrodome"), located across Klrby pucket pl.cs from thiMCDA Property; andWHEREAS, the MCDA Proporty has been devebped wlth a publlc ptaza (th.publcPhz6') and lighl rail Fdnsit station (th'Transit Station) as doplcted on Exhtbtt A, anachedhereto, and an underground publlc prtlng garage (pa*irq Garage'); andWHEREAS, trle Commlsslon deslres to enier onto that por{on of th6 publlc plazadBplcted on E)filblt B. atbchod hsrato (ho ?romFes'). in order to hold lvleuodome relatedevents and lhMCDA has sgroed to permlt lh6 cornrnlssion to hold Melrodome rehted events,from time to tims, on thPrmlses, sub.lsct to thtems and coridtuons of thls Agrernenq andWHEREAS, the Commission will be responsible under separate agreerenl Wth theMCDA for the cost o[ construcllon of a concession stand wlth restrooms and related slorageareas on the Premises (he 'Concession Facilitles') for use ln connection Mth its use of thePremisos; andWHEREAS, the Fodsral Transil Administration (the "FTN) ls provldtng he MCDA with$1,500,000,00 ln order 10 acqulre the MCDA Property for lhe development of the Public plaza;andt THEREAS, the MCDA and he FTA hava or witl Fnter into thal cerlain lnloragencyAgrment for Pass-Through of Congestion Miugation and Alr euatity Funds (the .CMAOAgroment") for the lransfer of federal funds from lhe FTA to hMCDA d for the impositonof crtaln federal rules, raquirannnts and approvals rega.dlng the dvolopment and use of thePubllc Plaza (the 'ClVtAQ RBqul.emenls'); andWHEREAS, this Agroemant ard th6 Commission's use of the Publle Plaza andPremises shall be sublect to th6 approvat of and go,remed by the FTA and he CMAeRequiremenls, including any moditlcatlons, cfianges and rBstdcuons hat the FTA may imposeupon lhls Agreement, the MCDA and the Commlssion; and

1

EXHIBIT C


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WHEREAS, fie MCOA belleves that the Commisslon's use o, lhe Public Plaza andPremises is consistant wlth the purpodas of the puDllc Plaza:NOW, THEREFORE, ln consideration ot the mutual prcmisas of the perlies conlaanedherein, lhe parlies hereto agree as follows:'1. Use and Rlqtt ol Entrv. The tvlCDA herby authodz$ hs Cominlsslon and itsemployees, agenB. coofactors or invitees tc enbr upon th6 PrBmises fro,n Um6 b tlmetor the followlng pu+os.s; and lhe Cornmission speclllcally agrees lhat lts conduct shallbe llmlled lo those purpo8es onl)n

Metrodome Relsted EvenE. Durlng thbrm of hls AgrErmgnl ths Commlssionis prmiUed to use the PremBes, from linre to time. for Metrodorne related evontsas approved by lhe MCDA heroln (lhe "Metrodome Evantr). Ttlo avltrodofliEv6r{s wlll cDnslst of eny pr@vent vont-{lm6 and post cyrnt qrldoo,qionlodand hospttality tsnt{rlented actMfles sdleiruled by or lhroh tle Commleslonor hE Mlnnesota Vlkings, Universlty ot Minnesota, Mlnn6oh Twins or ohermajor evenl users ol the l,tot dorDe (each, a 'Key Tenanf) b enhanca theMelrodome experlence for 'pafons in cofilunc{lcn witr evints held at thMefodome. The Commlsslon shall not usc or hold eny Melrldome Event on th6PremlseB wllhout lhe prior wrltton approval of lhe MCD{ As ol lhe dale ol t{sAgreement lhe MCOA has apprcrrEd th6 schodul ol Mstodome EvenE 8slisted on Exhilit G2003, attschEd herelo and Incorporated h6rein, to be held bytho Commission on hs PrDmlses during thB inital calendEr year of lhleAgrsemnt. During fitem of this Agreeoenl, [re Cornmlssion shall sr]mit tothe MCDA tho proposed schedde of Melrodome Evenb for each of the KsyTnants for eadl calndar yeaa as soon as such s.ftedule is available and(Bxcspl for maneE outsld MCDA'g rasonable control) thMCDA will grenteepdority preference for use of the Plemls66 in raspect of Kcy Tcnant 6v6flts. ThCommission will ,rsn linE to time submit lo tho MCDA, for MCDA approvalt anyother Metrodome Events and the MCDA shall ha're lhlrty (30) days aftor recaiplof such requost b approve, ln whole of ln pa4 the use ol lhe Premlses for sudrother Metrodorno EvEnts. The MCoA shall make neesonablo efHs toaccomrnodatg he proposod echEdule of such other Malrodone E\nE, Uponapproval of any Motrodomo Er6nls, a new E,6ibil C shall bauached herp sndIncorporated herein. The Commission may, at any tlrE, add additbnalMetrodom Events to trcurnt sshedule of Metrodonre EvenG upon th6 prior\wliten approval ol the MCDA The MCDA shall advlse lhe Commisslon lnwriting of any events it plans for the Public Plozo and wlll rlork with thgCommission to avold conflicts in scheduling 6v6nls on th6 Publlc PlazaConcession Facilitic. Notwithstanding any'hing in his Agreement to thcpntrary, the Commiss'ron shall have lhe sole righl trc usthe @ncesslonFadlltigs on tho Premisss and lo ksep and slore goods, equipment antl personalproperty thorn at all tlmes, Thts will lnclude use of ihs Concession Fadllties forMetrodorno Events beglnnlng ln April 2003, prlor to the,..pompletlon of lhe_Premisas or other pads of the Public Plaza. The Commission may upon reqrst'ot MCDA also provlde concesslon services for other adivrues on thPubllc Phzaon the same basls 6s thc sorylcas are provided for MetrodorE Events TheCommisEion shall keep and maintain the Concasslon Facllftles ln good order and

(s)

(b)


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(c)

(d)

(e)

(r)

condilion and shall use rcssonabl cflorE to scrrE lhem ftorn use by any olherpartlss except in connecllon with Nltrcdome Evenls, The MCDA shall have nollablllty for any darlage to the Concesslon Fadllties or any goods, Bqutpm6nt orporsonal property thorein or thoroon except as may be caused by he negligentor intBnlional torts of the IVICDAPermlls and. Aporo,s. Tho Commission shall secure or oause lts tsnanB toseanra, at no cost to the MCDA all permits, licanses and approvels necessaryand required for eadr of the Motrodome Ewntg to be heh on the Premiges,No Llem or Encumbrances. The Commbslon, ln lb use of ths Prgmlses, shallnot prmlt or grent any saourlty inierst ln, or oreato or allow lo oxisl, any li6ns,charges or encumbrances in or lo the PremlsesAoolicable Lawg The Commlsslon shall comply wlth all appllcable federal, stateand local lavn, ordlnances and reguhtlons ln lts uso of lhe Premlss.Hazerdous Waste. The Commlsslon, in itg us6 ol thB PrEmises, shall not norceuse lo be, nor alhw eny othe. person to deposft, store, dlspose of, place o.otholwlse locate or sllow to bs locgted on or wittln the Premisas, any hazardoussubstances, hazardous wastos. pollulants or conlamlnants, Indudlng petroleuft-based producG, as thee terms ardefined under any federal, Slate ofMinnesota or local stalule, ordlnance, code or regulation, 6xa6pt sudt hazsrdoussubstances as er6 ordinsrily usad ln and necesary lor he lvletodome Events,provued that sudr use ls in accordsnco wlth all appllcsbl laws, end that ln theevenl eny such hazErdous substancgs ar6 found on or wilhin tho Premls8s,arising out of thuse of the Promlses [or a ilbodorne Evsnl thComml8donshall lndemnity the MCDA as provlded in Secdon 3 horcln, subjed to no slatutoryor insurance limitations-Evant Se(uo and fakedown. The Commissbn siall be alhwed et least one fullday prlor lo the day of a Meuodom Event ln uhidr io mako o+Premieespreparalions and setup, and shall have reasonable pea'rod not to exceed 24 hoursan6r 8 Met odome Evont (subJecl to malters outsHe the Commission'sreasonable control) ln which to take down any equipment, tents, tralets, lablos,seating, elc., used for sr,rch Metrodome Eynt and claan up th6 PrEmLsEs. lnundertaking the selup or takedovfi adi\4tos for or holding any MetrodomcEvents, he Commission, lts employees, agentg and contreclors, shall not placeanything on ths Publlc Plsza whldl excceds lh6 lod limib as set out in E)fibilD, nor do anything that will unduly intorfere with or disrupt or impede the MCDA'Suso and possession of tho MCOA Property or wilh rEasonablg access to andoperation of tie Translt Stetion and associated lighl rail hansit llneFees and Costs. ln conslderatlon or lhe Commissioo's obligation to maintah thoPublic Plaza es set out in Sc{lon 1(l), there shall be no fee for use of thcPi6mises by thCommisslon gr its tnants. The Conmhsbn Eill bo rFsponsiblefor the cost of all seMces, equlpment, labor and rnaterials used in conductlng lheMetrodome Events on th6 Pramiss.

(g)

(h)


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(l) Maintenance of Publlc Plaze. The Cornmlsslon wlll be rosponsible at f'B co6t folkeeping the Public Plaza reasonably frae of l,?sh and debrts and for refirving ofsnow and lcs from those sidewalks and olher po.ilons sl tho Public Plaza shownon Exhibit E (whlch arB intended to bused lor pedestrhn access to th6 TransitStetlon) and from othBr portons of the Premlecln connecllon wilh rny u8e ofthe Premises by the Co.runlssion for a Metrodome Event llowever, MCDA willensura that all trash and debrls generalgd by any norFMetrodomo gyents on thePublic Plaza ara prompty rsmovBd and dispGed of lollorrdng ule ov6nt al nocost to the Commlsslon or ik ienants, The MCOA at lts cost will a)so rDalnlatn,repalr and roplace any struclural and othff Elomonls and equhmont cdrnprlsingthe Public Plaza, change lighting bulbs as neded, and oherwise keep he PublcPlaza (lnduding tho PrBrnlgs) ln good order and condilion, suitable for uss as aTransll Stat'ron and oher public uses.


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Hold Harmless and lndemnltv. The Commlsslon sh6ll d6f6nd, prot6ct, lndemdty andsave thMCDA ils agents, officers and employees, harmless fiom and against any andall llablli0es, lossss, damaoes, msls and agnses, including reasonable atlomeys fe6.from any act or negligonca ol Commksion, ils ofllcers, employees, agents, seNanlr,conlractors, or invitBes, arising out of ths Melrodome Evenls as related to lho Premises,Bxcepl for the negllgent or imenuoflal torts of the MCDA. The extenl ol lhe Commlssioo'sliablllty hereunder is limlted by Minnesota SlatutBs, Sclion 466, md lhe lnsurancopoliry as descibed ln Section 4 herein.lnsuranc.A. Commission's lnsuranco, The Commissim shall mainbin general liabilitylnsunnce, includlng prsonal lnjury fiability coverage, applying tn theCommisslon's use o[ the Pr6mlse3. The Commlsslon shall namc th. MCDA Esan additlonal insured undor he policy wlh respect to vlcarlous llabillty to thirdparties (ttird panies' to exdudinsurod parths) arising out ol Met odomcrelatd e'/ents on the Premb3, and wlll provide proof of such liebility insurancc

at the llmo lt exeqJles this Agreement The Co.nmlsslon or lts contrectoG shallprovldo dram shop insurance at all Met odome Events where alcoholicbovEragB are to bB rsNed on lho Premlsas-B. Tenants. Vendor's and Conlrado/s lnsurance. The Commlsdon shall reqdro ltstenants, vendors, contracto{s nd otlgr third parties who use the Premises lnconluncllon with MelrodonE EvenB to provldg worted oompensaflon insuranccoveEge foi Ell employs tvorklng on the Plmbgo to the Xent lhat suchinsuranis required by law. The Comn$sslon shall also reqrtrre such par[es tomalntain gneral llsblllty insuranco and, if motor vshhlG wlll bo utlltred lnconnection with E partys we of lhe ftmlsos, automoblle liability covorage, eadrwith llmlb of at least $1,000,000: and sald liabllity pollcy(les) shall narn6 lheMCDA as an additional insured. The MCDA shall be provlded wlth a copy of the

insuranc oartiflcato prior 10 any enlry upon lhe Premises. Such copy may beprovided to the MCDA by lelefax, and the MCDA shall provldo lho Commissionwith a telEfax number for sudt purposeConditjon of Premlses. Durlng any Metrodome Event, lhE Commission shall keap orrequlre its tnanB to k6p lhe Premlsos in neal, clean and safe cordltlon, TheCommisslon agres not to rnake any linprovEmnls on lhe PImlses wnhout thprbrwritten approval o{ the MCDA The Commission furlhar agroa8 lo promplly r6pelr orrgplace, at thE Commlsslon? sole cost gnd g)qonsg, any inprovemenb damaged lnconnection wih any Metrodomo EvenL The MCDA shall giro lhe Commission no lessthan 90 days' notice (or suctr slorter notlco as may brequired in en emergncy) bforsthe MCDA nnkes any lmprovements on lhe PrEmises that will inlerlere ln any matedalway wih the Commission's rights to use ol lhe Premlses as granid herelnCoordlnatlon. Each party shall appolnl a coofdinator with authority to ad or respond onits behalf conceming thsc,\eduling of evants on tie Publlc Plaza and..gther rnattersrequiring lts epprovel or consent und6r this Agraernnt. The MCOA'iniUally appolntgRichard Victor as lts Senior Proied Coordinator, at 6125735026, and ths Conmisslonlnltially appolnts Steven l\4akl Bs its Proiect Coordlnalor, al 612-33+Gi13 Upon any

3.

8.


18/33

termlnalion of any such appointment h6 appointing party sh8ll promplty deg'tgnate tothe other party in wri$ng the replacemenl coordlnator to carry oul suci responslbllltles.7. Defaults and Remedles.(a) Defautts. The Commiss'ron shall be in defrault of this Agrcoment upon elther ol thefollowing events: (l) fellure to pay wh8n due any paymnt ,quired to be rndeunder thls Agrernnt; or (il) failure to perform or obseNo any condillon or lEmreq uired to ba performBd or obsorved underlhls Agreement.(b) Notice. Upon the occunence of one of the venls of delault specified In Sectbn' 7(a) hreln, lhe MCOA shall givB wrttten notlca to ths Commlsslon speclf,/ing: (t)lh6 vent of default (ll) thB action roquired to curo lho evnti (iii) a dalo not lessthan 30 days for monetary dfaults and 60 days for nonmonetary detaulk frofiithe data the notlce ls malled io the Commlsslon by whictr 6uch delault must becurd (provided that il a non-monoEry detault cannot reasonably be oJrsd wlthln60 days, thB Commlsslen shall have up lo en additonal 00 days, if ncoessry, locure the delaull)i and (iv) lhat tailure to cutsucfi dcfault on or bebre he dalespEclfled In lhe notice may result ln the MCDA exorcirlng one or morof lheremedies listed ln Section 7(c) herein.

Remedies. Upon the occurronce of any event of default ss deflned ln Seclhn7(a) hereln, and notica as provlded in Sedion 7(b) heoin. the MCDA, at itsoption, in addition to any olher mnredles to which it mlght by law bentltled to,shall haw trrilght lo do one or mor6 of the {ollowiry 0) to canc lh'l!Agreemnt (ii) to trminab ttre Commlsslon's use ol and r,gtd ot entry lo heP/emlses as granled h6reln; (lll) to brlng appropriate adion to enfoc sudrperformance or observancs and lhe coredlon ol sudi fallurs o( dotaulU (fu) todedare lhe entire unpaid paymenb dua and paysbla horrundet, irDrnodlet6ly du6and payable without presentnent, dernsnd, prot6t, notlcs of dlshmor or anyother nollca; (v) lo suspnd he MCDAs performence under his Agreonrent andthe Commission's rights to use and enter the Premiss durhg tho contlnuance ot.'the event o[ deraullRemdles Not Exdush/e. No right or rsmsdy by hb Agresmant or by Bnydocumenl or lnstrument delivered by the Commisslon pursuant herBto, conFotredupon or resarved to the MCDA sfla be or ls lntended to be exdushre of anyother rlght ot remedy, and eadt and vory dght and remgdy shall b6 c{,mulaUveand ln eddition to any othgr.ight or remBdy nolr, or hercafter exlstng at law or lnoquity or by statut.Waiver: Forbearance. Excopt as the MCDA may hereafter ofier#se agrso In.vrriting, no waiver by the MCDA ot sny brrech or default of th6 Commission, ofany of lts obligatlons, sgrcoments or covsnants under thls Agrrnnl shall bedeamed to be a waiver of any sr$sequent breach of thsrne, or any olherobllgatlon, agreemenl or coyenants under his AgrEemeht. nor shall anyforbearance by the MCDA to seek a remedy for suci breach be dEmed a walvtrof its rights and remedles with respect 19 such brEech, nol shall he MCOA bedeemed to have waived any o, tts rlghts and rgrnec,ies unless it be ln wigng andexecuted wilh thEam formality as lhis Agreement

(c)

(d)

(e)


19/33

8. Mlscellaneous.(a) Notlces. All nofices provlded for herein shall be In witing and shall be deamed tohavo bean given when delivered person8lly or when deposited ln he UnitedStates mall, regislered or cenifpd, postage p{epald, addressed as follols:To tha Conmlsslon,' I'lotropolltan Sports Facililies Commission900 Soulh Fnh $reetMhneapolis, Minnassta 5541 5Ath: Excuflv DtEclorTo the MioA: Minneapolls Communlty Oeveloprnent Agency105 FiflIi Avenue SouhMlnneapollE. Mlnnesota 55]l()1 -2534

Attsnlbn: Executve Dlrrclor(b) Govmino Law. Thls Agremont may be condrued and enfored acoordirE toand govmd by th leurs of lhe State of Mlnn$ota.(c) Counteroarts. Thls Agreoment may bo ereolted ln any number of countorparts.all of whlch shall conslituts a stngle agreement, any one of wtrlcfi bdaringslgnaturss of all partles shall be deemd en odglnd.(d) Eq'l'ime is ol th,o ossencaln the performance of lhis AgreemenL(e)EntlreAoreemen]LThisAgreernentcontainslheentlreag]eementofthepartioshoreic on tho rnattErs covered hereln No othar agrsemr( statornont orpromises mads by any perty or by any smployes, cfiicsr, or agent of any partyhereto thEt ls not ln wrlting and slgned by all the parties to thls Agreemont shallbe binding.g. Scope of Use and Rloht of Ertrv. The grant of this Usa and Right of Enfy to theCommission by tte MCDA shall b6 nonassignable except lo a successor public bodyand shall not @nfr any eslat, tite, or exclusive possessory rights in thc Promises t6the Commisslon, and may be termlnated for carne as pmvldd ln Sec{on 7 hereln,provided that the prcvisions ol Saolion 3 hemin ahall survivo termkration of th's UseAgreement and Rlght of Entry


20/33

lN WITNESS WHEREOF, tllg panies herolo havB exocutd flb Agrcemenl as of thday andyear tirst wdtlen abo\roMINI',EAPOLI$ COMMUNITY DEVELOPMENT AGENGY,, Cr/T l+lB Daputy Executfuc Dlreclor

(signatur8 page to usB Agreement and Rlght ot Entry)

AssistahlOevelopmenl Counsel


21/33

M SPORTS FACILITIES COMMISSION

By

tuid By

(Signature page to Use Agreement and Right of Entry)


22/33

Exhibit AfrSl{r'''*dra,".,. __ aoliIrd5it cr lr .lrlsE66 lltltrr

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site plan

downtolvn easUmetrodome lrt station afld plaZe8.m;d 5llcl ord *rehrrstAUE{ Ldtu


23/33

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24/33


25/33

sEcnoN 01010SUMMABY OF WORKExhitrit DPrrl

PAHT 1 . GENEMT1,1 SUMMARYA S6clbn lrEludag:I Drscrip(lon ol con6truclk n dofivsred urde. a singlo coouac]2. Besiridions rhat sflect oonstuclion oporaliorE3 Us6 ot buiid,ngs, premlees ard site,B B8laled Seclihs:1- DcumBnt m70O . G.neral CmdliorLi.2 SBclion 0101 1 - Summary ol Mu[ipto Coilrack3. Seotion 01145 - Slte Managemen!4 Sctjon o 1290 - Price and Payrnent Prccdures.5 SoctioD 0 , 630 . Prbduct Oplin3 End Slbstltutions .1,2 GENEBAL SUMMARY OF YUOBK A'ID ADdTIOI'IAL DEFIIIITIONSA O,xrrer: Minneapolb Cornmunlty Olvul@ftonl Agoflcy (MCDA) and,

'l . Ormods Tenanl: Metropolllan Sports Flcllhts Cornmissbn (MSFC),B Projcct Locallon: Block bordered by Pai( A$nu Soulh, Klrby Pucken Plcca, 4h S\resl Soulh End5!' strest south.C Gnaral Scope: ThE proi6l, Oonsiruclbo PekrE|c 3 (CP-3), consist! o, conslrrction ol lhs dEza,arcadE, concesslon and rostroorn bu!&Es. and lh" m*zaninc lor thc Dorrntorm Ean LFT S'lationPlaza as desoribed wilhin thsoopc ol lh6 CoflEact Oocunnls.1. Work lnclud.d: Provide lsba( rnaterlBb, ardcleg, equipmrnl, incid.nt h, item8, tools, sgrvices,supplies. mthods, oprcrelions, skllls ln such gu.n0ties rs rmy bc noEssryb cornpl.icproiect wlthin intent ol ltE OonfBct thcumerf!.2. Singular notsllons thall bE consideEd plurBl wtdre pllIsl applicslion ls rBarooabty inter.bl.Mention or indilation o, extont ol wolt und6r a,ry wo divilion or spocllbalioo sgcttxlI8 donoonty tgr conveniance ot Contractor and 6ha,l nofbe conslrued as dicriung dl woi< r*luircduader lhet Oivigion or SoclimD Conskuction ContracE The const.uction ot CP.3 will beccomplishd rrndr a shgle PrimaConlr*LE. Consrrutrlbn Limlts: Exospt as Epecilically lndrEled or as may b necassary ie compleie iho tvorkundar lhe contsacl, activities ol th. contract shI be llmited to wllhh $e limits rbrigtralad by thgDrEwings End thp g$mol

.I.3 MILESTONES OF WORKA Construct'on ol CP-3 plaza has thr lollotying milE6tone dal3:- I Mllsstone Dattlo 1: Compbt consin clion ol ConcossioniToiht Buildlng by April25, 2003.2 Mil6slong Dale No 2: Compl3 construction ol ArcEde plars 3, 4. 5, and 6 strEbrd steol

lramework and lrain station sida masonry by Junc 2, 2m3, b alory st uctrnol altaohmsr olLBT ovorhoad oanopy b,y LFI Contastor.l_ 3 MilGlone Data No.3: Substanlial Completion ol ntire proiecl by Spt3mber 5. ZO0E. f[--r.o .rrr* oF coNsrBucrroN LoaDr,.G or{ pLAza LE,EL ttlI A construcl'ron loading oo fio PlEza L6vBl shall nor exceed the slruclurG dGcign fve and daed loa&L II The suucturd.sin [vs ard dotd bads erD: II Dowriowr E.h !.RT Sflticn ptse0?01.012.12 - Cg-s ph.:. - CD Nol! rbar '12, I,CEA 01010. t


26/33

L1.512.5.

25O pounds pcr tgtrarE loot unllorln iw lo.d.135 pourds pr squBrE lool utilom (bad losd.Colcnlratd livs loads arE nol lo Excecd sn ilohlrd Hs&I aJo lo6dng; dso not ilcomblnation wih the doEign unllonn llve lggd Or other oon6ntralld loeds.EASEMEhITSThe MQDA has granled pe.manent eagcmenb to hr HPO for the Do,rnryn Easf LRT Stllioo andlrac*s, ard the MCDA ha! also granlod temporary conclndon oas.lFnts lo lhHPO tror hcconstruquon ot lho Downtown EEsl LBT StEl'ron 9rd ItadG. Thc sdrcdrlo Ot Cotl6tlElion d lhcportlon ol the arcade lncludng phrs 3, 4, 5, lnd 6 b oducal to b9h Fi.cts. Th. cornglotot ofthese drs incJudng the rDasonry yarperls ,equiDd tor th! LITT Coalrlcbr b insb[ a suio.tcanoPy sEust re Ths CP-O Conlractgr sharl coopcrsb eIrd coordinatr H h tE IJ|T Contlciors.ThE MCOA wlll Essi8t in lho coordinltlon ol thss pft,i.qts.

PAHT 2 . PRODUCTSNot UsedPART 3 . EXECUTION3. l SUBGOI',TAACTOFSA Th6 ContrBctor shall not award any work to any Subconbsctor witho.I p.ior approval ol thOrynarand fuchitsct. Approval wlll not bgivsn un6l the Cor nctor slbmits lh. Liet ot Sttcontr8cbrscontainirq srrch hlormadon as the Owner ard Arctrltrcl may rcqulrc concemlng the proposcdSubcornractor and the scopg ol the eubcontrect. (Bet3r to Seclion 01330 - SL6.nl[elB)3.2 USE EY OWNEB (FEFEB Al.sro TO OENEFAL CONDTTTONS)A Tha Owner reserves he righl to bt olh, cofllracts in co.ri5ian whh lhis ProJc]. Thle ContraclorEhall allord otha, conlraclora Gssonabrs opporuflity lor lhs lnlrodrctifi ard sioragot lhrirmateiials and execsrion ol rheir work, and sha proparry conn cr and coodinalg tfa wod< witr

lll.lrs. - i-B TtE O$rnr rBsaives lho rigtt lo lointy Hl,py th! pr.rni6o6 with tre Cofitraciots h thc F.rlofmalcsol his dutie6 end funcliofls Tha Owner EJso riservee tre righl to: sI|lcr lnlo ths ptojrct andpramisB6 at all tjmes: mEk! i.rstallstions ot mstBriel8 and cquipnrant a epproplhf tmca as iheWork prsgross8s; inslall eqdpmer( fuhitur and furnlohings wtren +accl eic u rpproprtsrslages o, comPlelion Contraclors slEll coo.dinal $'Drft wit r Urc Own6r ard coope.aie nm OeOwner to minimize urdu ir srlsrencGC. lf any par1, unn, phasa, or the cndr3 Project ts Er.Osiantialv compl6tE or lt dy for occupancy, lhoo!$Br lllay, upon nouce to UE ContrtotoB, 8nd wlthout prudce b ,ly ot tii3 nCrE 6t Up Oflncror Go ntractors, elter into end make use o, $o Work thai ls ir:tstamlff corpfefc.

.. 3,3 MAINTA'NING SEHVIqEE AND FUNCNONSA w;rk at occrfiod Faci[ties: Aier owner's occrparE? (rrJlr or pardar) or rho p1ri.ct or any ,,rr,BEge' phase or arsB, any yvork romarnrng ro br accomprished ln ths occwld spaces sh;ll be doisin cooperafon with, and apprcvat by. fi.-o'vnor and sciedulad ln aOanci *ln tre orr,rror. tngonsral r|ork in occupled spaces tharl bc dqra lrin lhe spBcG iE not in ugs, gtdt astBrbt hou.E in,adminisralive areasi or prblic spacas whon publb use horri are owr lor the 6lgy, ur*is specmc&y'approved by Uta Ov/nBr, whcrE ncooss6ry. overdmG Ehall bLDd ll fiE work a t/tot roar6naUfy bEaccomplishsd durinp normaluork pedo$, El ng Ertra coct to ihOuilcr, Work in oc"pi"O ao&3hsl bperformgd in a mannor and st Euch {me a! wlll not Elgniflcrrdly htsrtore with, liampeiorlnconv8nhnce Owng/s progrlm or funstjons, .

LfIit ;?!t

DolU oun Eost LFT Stailon Fl6-Js0781{12- 12 - CP.3 ptazE - CD Surhmary Dt wdt0ror0 - 2oveftbar 't 2, ZOO2

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27/33

Exhibit E;. *'e.A--=Nr- E-


28/33

EXHIBIT D

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29/33

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30/33

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32/33

ALAFtlSLCMinnesota Sports Facilities AuthorityMinnesota Spons Facilities Commission900 South Fifth StreetMinneapolis, MN 55415Attn: Ted MondaleRe: Use Agreement and Right of Entry - Notice of TerminationDear Ted:

I am writing on behalf of Minneapolis Venture LLC, the fee owner of the real estateknown as Downtown East and the "Plaza" located on that real estate. This letter provides formalnotification to the Minnesota Sports Facilities Commission ('MSFC') of the termination of theUse Agreement and Right of Entry dated September 17,2003 ('1he Agreement!'). This is theAgreement tlat was the subject ofa May 30, 2013 letter from you to me and the June 7 responseto that letter which was sent fiom Norman Baer to David Trevor.

The Agreement was effectively terminated when the MSFC was abolished in 2012pursuant to Minn. Stat. 5473J.25. We understand that the MiDnesota Sports Facilities Authority('MSFA') disagrees and claims thar il stepped into the shoes of the MSFC witl rcsPect to therights and obligations under the A$eement. For purposes of this notice of termination onlY, weare not debating the MSFA contention which is why this notice is addressed to both the MSFCand the MSFA.

Pursuant to Section l(a) ofthe Agreement, the MSFC is required to provide an advancelist/schedule of "Mstrodome Events" for wh.ich it plans to use the Plaza. Please provide such aIist so that Minneapolis Venture may exercise its right of approval. As specified in theAgreemenl, please recognize that MSFC is prohibited from conducting any Metrodome Eventswithout the prior written approval of Minneapolis Venture.

U.5. Bar


33/33

Also, please take notice that pursuant to Section 2, the Asreement will termapate as ofOctober 31. 2013. Absent a new agreement, the Plaza will not be available for use for any ofthe four home games in November and December or for any possible playoffgames in early2014. As previously stated, Minneapolis Venture will consider and negotiate in good faith withregard to any proposal that is made for an extension beyond october 3l until such time as theMetrodome is "no longer being operated as a spofls arena for regularly scheduled college orprofessional spons" (a period that we understand will end with the end ofthe vikings 2bl3-14season when the stadium is scheduled for demolition). I note that the Minneapolis vennrc hasnot yet received any proposal for any extension ofthe Agreement.

Finally, pursuant to Section 2 of the Agreement, Minneapolis venture will expect yourorganization to promptly remove all "trade fixtures and personal property" fiom the plaza rpontermination of the Agreement. Please rnake appropriate arrangemenls in advance so that pr;cessis not delayed.

Robert C. LuxManagerMinne apolis Venture, LLC

Date post:	02-Apr-2018
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Minneapoils parking lot dispute

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