HomeMy WebLinkAbout1995-08-14 MinutesMINUTES OF A MEETING OF THE CITY COUNCIL
A special meeting of the
Monday, August 14, 1995,
Administration Building,
309
Fayetteville City Council was held on
at 4:30 p.m. in the Room 326 of the City
113 W. Mountain, Fayetteville, Arkansas.
PRESENT: Mayor Fred Hanna; Aldermen Stephen Miller (arrived
late), Kit Williams, Cyrus Young, Woody Bassett, Steve
Parker, Jimmy Hill, Len Schaper, and Heather Daniel;
City Attorney Jerry Rose; Clerk Typist Jane Heth;
members of staff, press, and audience.
CALL TO
ORDER
Mayor Hanna called the meeting to order with seven aldermen
present.
INCINERATOR LAWSUIT THIRD -PARTY LITIGATION - ATTORNEY SELECTION
City Attorney Rose, who had requested the special meeting,
reminded the council of the reason for the meeting. The Legal
Services Qualifications Committee brought to them three unranked
recommendations for attorneys to represent the City in potential
third party litigation involving the incinerator lawsuit.
Statute requires that the selection be done this way. The
statute prohibits competitive bidding to procure professional
services and has been interpreted to prohibit the consideration
of price until the most qualified firms have been selected and
negotiations begun. Accordingly, the price of the services is
not to be considered in the selection of the most qualified.
However, it is proper to question the firms as to the method by
which their fees will be determined, but not the actual price of
the services to be rendered.
Mr. Rose further advised that the merits of this lawsuit, the
specific causes of action, and the specific firms or individuals
to be sued are not issues for today's meeting. These issues have
relevance only in determining the candidates' familiarity with
the project and their capability to perform the work within a
limited time frame. This is not a meeting to discuss generally
the incinerator project. It is a meeting to specifically select
the most qualified attorneys to advise the City as to the third
party claims.
Mr. Rose stated that the evaluation forms should reflect each
alderman's ranking of the firms. This is a record of their
votes. The evaluation form is a ballot and should be signed.
The four criteria listed on the ballot are required by statute.
The percentage marks, possible points, are part of the City's
personnel policy and went out with the RFQ. They can be changed
by majority vote.
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August 14, 1995
Mr. Rose outlined the format of the meeting. Each firm will give
a ten minute presentation. After all three presentations are
made, the floor will be opened to questions and discussion.
In response to a question from Alderman Basset, Rose said the
evaluation factors, which are set by statute, could not be
changed; but the possible points, which were sent out with the
RFQ and established by personnel policy, could be changed.
Alderman Basset asked how the votes would be tallied. Rose
explained he would give the ballots to the City's Purchasing
Manager, Peggy Bates, who would determine the points of each of
the three. The one with the most points is first, the one having
the second most points is second, and the one with the third most
points is third.
Ben Mayes pointed out it will be the one with the most first
place votes who will be selected. If there is a tie, second
place votes will be counted in.
Alderman Bassett stated he wanted the opportunity to explain his
vote to the public, whether the Council voted that night or not.
Alderman Daniel asked for an example of changing the total number
of votes. Rose acknowledged the points for each criterion could
be changed but cautioned against spending the whole meeting
deciding what the points should be. Before the meeting started,
he'd been asked by several Council members if the system could be
done away with and replaced by a simple ranking of first, second,
and third choices. This could be done by a motion to amend the
policy for this occasion.
Alderman Schaper stated this is a standard way to rank and is a
good framework that works.
Alderman Williams stated he would be more comfortable with a
simple one, two, three ranking.
Alderman Young agreed and said Peggy Bates would kick it back if
there was a tie on a ballot.
Ben Mayes stated ties would not be allowed.
Alderman Williams made a motion to rank the firms one, two, and
three, and not use the point system. Alderman Parker seconded
the motion.
In response to Alderman Schaper's request for affirmation, Mr.
Mayes said he believed Attorney Rose had said this was okay and
it was the Council's prerogative to decide how they would make
their selection.
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August 14, 1995
City Attorney Rose asked the candidates if they had any
objections to the one, two, three ranking. No objections were
given.
Alderman Daniel asked for confirmation that the factors listed
were the only ones they could consider. City Attorney Rose
assured her that by statute only those factors could be
considered and no others.
The motion passed by a vote of 7 to 1, with Hill voting no.
Attorney Rose stated the presentations would be made in an order
arrived at by random drawing. John Lisle from The Lisle Law Firm
in Springdale was the first to speak.
Mr. Lisle reminded the Council of his firm's involvement in the
recent past with litigation that involved the City of
Fayetteville. As stated in their written statement of
qualifications, they would be willing to represent the City on a
contingent fee basis. They would also be willing to represent
the City on an hourly basis if that is what the Council chooses.
It had been their understanding that the City was looking for
someone to work on a contingent fee. They work both ways and are
willing to handle the plaintiff's cases on a contingent fee
basis, advancing the cost to be reimbursed on the successful
conclusion of the case.
The counterclaims or other suits brought against the City would
be defended on an hourly basis. The City should anticipate that
it would become a defendant in litigation and it can't defend
itself on a contingent fee basis.
The Lisle Law Firm is a small firm with five attorneys. They
have handled a suit almost as complex as this in the recent past.
They also have familiarity with all parties involved in this
suit. They are set up to handle this case in their office or in
association with outside attorneys whose help they would require.
Hiring outside the office would be part of their advance costs
and allows them to handle much that would seem beyond the scope
a small firm.
In response to a question from Alderman Williams, Mr. Lisle
confirmed that the hiring of outside attorneys would be part of
the contingent fee, absorbed as though that person were part of
the firm. If they were defending a claim, however, and had to
employ someone outside, then that cost would be passed to the
City exactly as billed to the law firm.
In answer to a question from Alderman Parker, Mr. Lisle stated
the costs would be subtracted before the contingent fee would be
determined. This is negotiable.
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August 14, 1995
City Attorney Rose asked that any further questions be held until
all three firms had made their presentations.
The second presentation was made by Mr. Thomas M. Ingoldsby of
McDermott, Will & Emery, along with Steven F. Pflaum. Mr.
Ingoldsby is a bond attorney by training with a substantial part
of his practice being legal matters associated with financing of
state and local infrastructure projects. In recent years, a good
amount of time has been spent on projects financed by bonds that
have gone into default. Mr. Pflaum is a litigator who
specializes in municipal litigation.
Mr. Ingoldsby was originally hired by the City in 1988 after it
decided to withdraw from the incinerator project. The scope of
the work was to advise the City as to the legal issues and its
responsibilities arising from the termination of the project.
They first advised the City that it had a clear contractual
obligation to make the payments due on the bond. They also told
the City that there was a substantial legal question as to the
enforceability of that contract. At the same time, they informed
the City of the serious consequences to their credit rating. The
City was contacted by the rating agencies in New York and was
advised that failure to honor their contractual obligation would
have a serious economic impact on the City.
The second thing they advised the City was that in addition to
its obligation under the waste supply agreement, if it didn't
make the payments it could be sure it would be sued by the
trustee on the bonds.
The City had asked them to look at the question of its ability to
recover claims against third parties. The firm told the City the
possibility of recovering a significant amount of money was
unlikely as long as there was an outstanding obligation to make
the payments under the bonds.
The Supreme Court decision brought to conclusion the first
question as to the enforceability of the agreement. It is now
time to move on to the recovery of any damages against third
parties and the defense of claims that can be raised by the bond
trustee against the City.
According to Mr. Ingoldsby, there are essentially two issues the
City should be looking at. One is the attorneys' fees. The
second is what its potential liability is to bondholders for any
shortfall. The larger risk is the $14 million shortfall, but the
fees of the attorneys will not be an insignificant item no matter
how they are calculated.
The City should consider the source of funds it has for the
payment of the fees. Any recovery the City makes is to its
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August 14, 1995
advantage because it reduces its potential exposure on the $14
million but it does not automatically translate into the City
having money to pay new attorneys' fees or to recover costs
already invested in this project. McDermott, Will & Emery is
prepared to work on an hourly rate basis, as they regularly do,
and are prepared to work on a substantially discounted rate
together with a modified contingent or success fee. Mr.
Ingoldsby gave an example showing that under a contingent fee it
is possible that the dollars paid out to the City will be more
than on a fixed-rate basis, but the City may have to come up with
additional money to make the payment to the attorneys.
Mr. Ingoldsby concluded by saying his firm has worked with the
City before, knows the facts of the case, has analyzed the issues
and would be pleased to pursue to its conclusion the final phases
of this transaction.
With a few minutes left in the presentation time, Mr. Ingoldsby
asked Steven Pflaum to address a couple of the major issues of
the case. Mr. Pflaum focused his remarks on the question of
where the City stands in terms of the incinerator litigation and
where to go from here. The Supreme Court decision means the City
does not have any contractual liability for the payment of this
shortfall, but the City still faces significant potential
liability with torte or securities claims. The shortfall will be
paid by FGIC. When that happens, FGIC will become subrogated to
the claims the bondholders have against any third parties or City
of Fayetteville. There is likely to be litigation in New York
over whether New York or Arkansas is the proper forum for those
claims. McDermott, Will & Emery is well positioned to deal with
that eventuality. They have a New York office and are
experienced litigators in that state.
The City itself has potential claims against third parties. The
theory of the third party claims, in essence, is that these other
entities are responsible for the bond offering going forward, a
bond offering that was predicated upon an illegal contract. In
addition to recouping whatever share the City might be determined
to have of that shortfall, the damages of the third party claims
would include attorneys' fees incurred in prior litigation as
well as the losses associated with damage to the City of
Fayetteville's credit rating as a result of what's happened.
After more than six years of litigation, the City is on the brink
of another round of litigation. One that could turn out to be
more imposing than what has gone before. The City now opposes
FGIC, the trustee, and five others. These parties are
resourceful, well-heeled, and skilled. It is critical that
whichever firm you chose has experience in this kind of
litigation --legal malpractice claims, securities litigation --and
will have the necessary manpower.
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August 14, 1995
The third party claims do provide a potential way out for the
City. Mr. Pflaum believes there is value to those claims and a
way for the City to reduce its potential exposure. This cannot
be walked away from because the City is going to be a defendant,
is going to be sued.
The third and last presenter was Dick Patton of Patton Law
Offices from Texarkana. He believes any party who has a claim
against the City and any party whom the City has a claim against
should be included in this lawsuit. He includes those who have
contingent claims against the City.
Regarding the fee, Mr. Patton works only on contingent fee basis.
He has been a plaintiff's lawyer for 25 years. He does not do
hourly work. He has handled many legal malpractice cases and
securities work. He sees this case as a bad advice case,
malpractice either by attorneys or A. G. Edwards or others giving
advice. It is not a simple case. He approaches lawsuits
aggressively, hiring needed experts. This case will need the
services of at least three, perhaps six, in different areas of
expertise.
Mr. Patton's proposal to the City is a contingent fee basis. He
will advance the expenses and if the City loses, he will be out
the money. That is the way he handles all his plaintiff cases.
Mr. Patton has three other lawyers on staff in his office. One
is an Arkansan from Ft. Smith. Regarding the contingent fee
basis, Mr. Patton will not be a party to collecting a fee more
than what his client receives. He has tried cases here before
several judges.
After Mr. Patton's presentation, Jerry Rose called for questions
and urged councilmen to be as candid as they wished.
In answer to a question from Alderman Young, Jerry Rose stated
the City is hiring attorneys to pursue third party claims, not
hiring attorneys to defend the City in potential litigation
against the City. The City could hire a firm on a contingency
basis and could hire that same firm on a hourly rate to defend us
if sued, though there are reasons we may not want to do so.
Alderman Williams asked if the City is planning to do any actual
hiring at this time or would it wait until the Supreme Court
decided about the petition for rehearing the City has filed. We
have no mandate at this time.
City Attorney Rose expressed his opinion that the City needs to
go ahead. If the petition for rehearing is granted and we win
this lawsuit, there still might be third party action the City
would want to pursue. He would consider hiring them as soon as
they are ranked, negotiate a contract, and bring it back to the
Council.
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August 14, 1995
Alderman Bassett expressed his concern over negative public
reaction if the Council chose to hire the Lisle Law firm at this
time. Mr. Lisle stated he wanted a chance to work with the City
of Fayetteville partly as a result of the sales tax case. This
would give him a chance to get back good will that may have been
lost. He also feels this is the right side of the current legal
question. His firm's performance in the sales tax lawsuit
demonstrated his firm's work ethic. They work hard, have a
record of success, do the work on time and the right way. They
do not give up until the fight is over. All of this would
benefit the City.
Mr. Lisle further stated that the City is now changing courses in
their legal arguments, having once said the incinerator fee was
legal and now having to recover money because it was not legal.
The Lisle Law Firm would be a fresh face with no ties to any past
history of this case. They look forward to taking the side the
City is now on, to recover money for the City.
Alderman Parker asked Mr. Lisle and Mr. Patton if their law firms
would be able to support the case in a location such as New York
City. Mr. Lisle responded his firm would not handle that
litigation but there may be ways to avoid filing in New York that
he would not want to talk about in an open forum at this time.
In any case, the City would have decisions to make regarding that
matter.
Mr. Patton replied there is a substantial chance that all claims
cannot be pursued in Washington County because of venue statutes.
He would be comfortable anywhere in Arkansas. If something does
occur in New York, the City will have to get New York counsel.
Alderman Williams questioned Mr. Patton about his contingent fee
and his remarks on suing everyone at once. Mr. Patton said his
preliminary thought would be to preemptively sue all parties
suing the City that can be sued and to force the issue rather
than to hope it will go away. He cannot make any recommendations
until he has studied the issue further. As he does not do hourly
work, this would be done on a contingent fee basis. He would not
charge Fayetteville more money than the City would receive and is
willing to enter into a contract that stipulates that aspect. It
is possible, however, that a judge will award him money from
another source.
Alderman Schaper inquired as to at what point the fee gets
awarded in a contingent case. Mr. Patton said he gets his fee
when the the City receives its money. Mr. Lisle agreed that is
the way it works.
Alderman Daniel asked for a worst-case scenario of the possible
length of this lawsuit. Mr. Patton suggested 18 months,
excluding the appeal. He would add another year for the appeal.
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August 14, 1995
Alderman Bassett expressed his belief that it is in the best
interest of the City to get this matter closed as quickly as
possible. The decision about selecting a lawyer should be based
on which firm has the best chance to bring all the parties in the
case together in an effort to settle this litigation. He asked
all three firms if they agreed with him and if their firms would
be able to do this.
Mr. Lisle agreed it is in the City's interest to get this case
settled as quickly as possible. It is in the interest of the
lawyer handling a case on a contingent fee basis to get the case
resolved as soon as possible. They have already copied over 95
notebooks of material from the City's offices.
Mr. Lisle's associate, Joe Reed, added that mediation and
arbitration is in its infancy in Arkansas. Many judges will try
to informally mediate cases prior to trial. The Lisle Law Firm
has had positive results with this in their office. He has gone
to arbitration and mediation school in Texas and has met people
nationally who mediate professionally. He feels this is a prime
case for mediation. It is something his firm has talked about.
Mr. Patton agreed it is the perfect type case for mediation. If
it doesn't work, the City is only out the several thousand
dollars in mediator's fees.
Mr. Pflaum, of McDermott, Will & Emery, agreed that the objective
should be to bring this litigation to an end as quickly as
possible. He believes his firm is best poised to do this for two
reasons: one, they are already up to date with the intricacies
of this case and there will be no delay incurred here; and two,
they have an office in New York and have as many lawyers as
needed available to defend against the claims of the seven other
parties.
Mr. Ingoldsby added that you need to have the knowledge of what
is standard public finance practice, what is the standard of
care, how do these deals normally get done, and how does this
deal deviate from the standard practice. The McDermott firm has
this expertise and has made that analysis and knows, today, where
those flaws are and is prepared to proceed on them. Regarding
the contingent fee, they also have a keen desire to bring this
matter to a conclusion most favorable to the City.
Mr. Patton stated that he has litigated
Motors, Delta Airlines, and others. He
this meeting if he didn't feel he could
hire the people, and spend the time and
this business over.
with Honda, General
would not be present at
finance this lawsuit,
money necessary to get
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August 14, 1995
Mr. Lisle agreed that his firm understands the risks from an
attorney's point of view and is willing to spend the money up
front and take the case on a contingent fee basis.
In response to a question from Alderman Hill, Mr. Ingoldsby
stated that his firm would be able to deliver their services at
the same or lower cost than what is being proposed on a
contingent fee basis. The reduced hourly rate plus the reduced
contingent fee will be less than the overall contingent fee
proposed by the other firms.
Alderman Schaper asked City Attorney Rose for the reason for
keeping the third party claims a separate legal matter and having
two firms represent the City, one as plaintiffs and one as
defendants.
Mr. Rose responded that if the City's insurance company will
provide a defense attorney for suits brought against the City, he
would advise the City to avail itself of this. If the insurance
company does not do this, there could be some advantage to having
one law firm represent both cases.
Regarding a change of venue question from Alderman Schaper, Mr.
Patton said it could happen but is not likely. He would want to
explore the possibility and make sure we are safe with this
venue.
Mr. Patton said a proposal he planned to make if selected is that
the City, look very carefully at anybody it might sue and propose
to those people a mediation before the suit is filed, waiving
privileges and asking for documents to be furnished to a
mediator. If this could be accomplished, the City could walk out
of the mediation with potential liabilities over with. That
would be the best thing for the City.
Alderman Bassett reiterated his belief that getting this behind
us should be the City's number one goal.
Alderman Young said the possible settlement for millions of
dollars should not get in anyone's way when considering the
elements of right and wrong.
Alderman Bassett said he feels strongly that people in the past
blindly followed advice and that it is the Council's
responsibility to make the final decisions.
Mr. Lisle stated his experience with mediation is that no one
settles until they feel they are at risk. Mediation is a good
idea but there would still be a lot of work to be done.
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August 14, 1995
There being no further questions, Mayor Hanna asked for City
Attorney Rose's opinion as to whether a vote should be taken now
or at the next evening's Council meeting.
Mr. Rose stated a vote could be taken now or if the Council
needed time to decide, a vote could be taken at the Council
meeting.
Aldermen Williams and Daniel expressed a wish to take the time to
consider this overnight.
Mayor Hanna asked the Council to be sure all questions were asked
at this opportunity so the attorneys would not need to return for
the regular Council meeting.
Aldermen Young, Parker, and Williams expressed their desire to
have an opportunity to explain to the public their votes.
Attorney Rose suggested that the ballots be given to him after
the discussion at the regular meeting and he would give them to
Peggy Bates.
Noting that this meeting would be reported in Tuesday's
newspaper, Mayor Hanna questioned whether a public discussion
would take place.
Alderman Williams supported the council discussing this matter
but not holding a public hearing.
Alderman Parker wondered if the Rules of Procedure required the
Council to open all questions before it to the public. Alderman
Young said this was an option of the one presiding over the
meeting.
It was decided that the explanation of votes and balloting would
take place at the beginning of the meeting and that City Attorney
Rose would announce the results by the end of the meeting.
Mr. Rose commended all members of the committee and their
decision to present the three firms for the Council's selection.
Each firm was worthy of consideration. The Mayor added his
appreciation for the committee's work and for the firms
represented.
The meeting was adjourned at 5:55 p.m