HomeMy WebLinkAboutContractAGREEMENT FOR LEGAL SERVICES
THIS AGREEMENT, dated for reference purposes only as May 16, 2025, is by and
between the City of Renton (the “City”), a Washington municipal corporation, and Kaplan
Kirsch, LLP, a Colorado Limited Liability Partnership (“Attorneys”). The City and the
Attorneysare referred to collectively in this Agreement as the “Parties.” Once fully executed
by the Parties, this Agreement is effective as of the last date signed by both parties.
1. Scope of Work: Attorneysagree to providelegal advice and/or representation
on matters, as assigned or identified by the City, on thosematters related to the governance
of the City’s municipal airport, hereinafter “Legal Services.”
2. Communication: The City authorizes Attorneys to exercise their best
professional judgment to represent the City’s best interests in this matter. The City
authorizes Attorneys to make tactical decisions that, in Attorneys’ best judgment, are
necessary to pursuing this action. The City will determine the objectives of representation
and Attorneys will consult the City regarding the means by which the objectives are to be
pursued. All settlement offers will be communicated to the City, and no settlement will be
agreed to without the City’s consent.
Attorneys shall keep Cityinformed as to the progress of City’scase, including but not
limited to the status of any hearings noted with or without oral argument, and will send
copies of all important papers coming to and going from Attorneys’ office, including
significant correspondence, pleadings and other documents.Attorneys will provide the City
with sufficient notice of significant decisions arising in the course of the Legal Services to
allow the City to meaningfully participate in the decisions. Attorneys will not stipulate or
agree to procedural changes or limitations or other actions that materially impact the City’s
rights without obtaining the City’s fully informed consent. Such actions include, but are not
limited to continuing trial dates, stipulating to protective orders or other discovey
concessions/restrictions, and joint defense agreements. To provide “fully informed
consent,” the City must be provided copies of all relevant documents for review. Attorneys
shall receive written permission from the City prior to engaging other professionals to aid in
the representation, such as expert witnessesor consultants. Without such written consent,
Attorneys assume full responsibility for all costs invoiced by other professionals who were
hired by Attorneys.
Attorneys shall provide required updates to the following City staff at the email
addresses provided:
CAG-25-224
PAGE 2 OF 9
Martin Pastucha, Alex Tuttle
Public Works Administrator Senior AssistantCity Attorney
mpastucha@rentonwa.gov atuttle@rentonwa.gov
legaladmin@rentonwa.gov
If the Legal Services is related to a claim that has been or will be filed with the City’s
insurer, Attorneys will provide written updates to the City’s insurer regarding the status of
the case unless the City and Attorneys agree otherwise in writing. Failure of Attorneys to
communicate with the City as required by this section is a material breach of this
Agreement.
3. Public Communications: Attorneys shall not issue any news releases or
make any statements to a member of the news media or the general public regarding the
Legal Services without the prior approval of the City’s Attorney.
4. Time of Performance: Attorneys shall commence performance of the
Agreement promptly and shall timely file and serve a notice of appearance pursuant to
applicable court rules. All Legal Services shall be performed by no later than December 31,
2026.
5. Compensation:
A. Maximum Amount. Total compensation to Attorneysfor Legal Services
provided pursuant to this Agreement shall not exceed fifty thousand dollars ($50,000.00).
Compensation shall be paid according to the rate(s) or amounts specified below/in
Attachment A:
B. Attorneys agree that any hourly or flat rate charged by Attorneys for
Legal Services shall remain locked at the negotiated rate(s) unless otherwise agreed to in
writing. Attorneys will bill for hours worked in furtherance of the Legal Services. Hours
worked (i) as a result of an internal transfer of attorneys during the course of representation
under this Agreement, or (ii) preparing or reviewing Attorneys’ billings to the City or other
internal firm quality control procedures are not “in furtherance” of the Legal services within
the meaning of this section.
When Attorneys are close to incurring the maximum amount of compensation under
this Agreement, or upon the City’s request, Attorneys will provide an updated estimate for
Attorneys’ fees and costs required to resolve the matter described in Section 1.
B. Reimbursement. Attorneys will not be reimbursed for job related
expenses except to the extent specifically agreed herein. Routine costs directly related to
the provision of the Legal Services, such as filing fees and other court costs, legal messenger
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or process server costs, etc. may be reimbursed. Necessary travel expenses may be
reimbursable subject to the City’s written authorization and the City’s travel reimbursement
policy limitations. Fees and other expenses for expert consultants or witnesses will only be
reimbursed if Attorneys (i) obtain written prior approval from the City and (ii) include these
fees and expenses on Attorneys’ firm’s invoice, pursuant to subsection C of this section.
Other necessary and reasonable expenses incurred in litigation may be reimbursable with
prior written approval by the City.
C. Method of Payment. On a monthly or no less than quarterly basis,
Attorneys shall submit an invoice to the City staff listed in Section 2, including a description
of what Legal Services have been provided, the name of the personnel performing such Legal
Services, and any hourly labor charge rate for such personnel. The description of Legal
Services in the invoice should avoid revealing privileged or confidential information, and
should sufficiently identify individual tasks to avoid “block billing.” Invoices seeking
reimbursement for experts or consultants retained by Attorneys must be submitted to the
City on Attorneys’ firm’s invoice. The City cannot pay invoices issued directly from the expert
or consultant unless the City has separately contracted with that expert or consultant.
Payment shall be made by the City within thirty (30) calendar days after receipt and approval
by the appropriate City representative of the invoice.
D. Effect of Payment. Payment for any part of the Legal Services shall not
constitute a waiver by the City of any remedies it may have against Attorneys for failure of
Attorneys to perform Legal Services or for any breach of this Agreement by Attorneys.
E. Non-Appropriation of Funds. If sufficient funds are not appropriated or
allocated for payment under this Agreement for any future fiscal period, the City shall not be
obligated to make payments for Legal Services or amounts incurred after the end of the
current fiscal period, and this Agreement will terminate upon the completion of all remaining
Legal Services for which funds are allocated. No penalty or expense shall accrue to the City
in the event this provision applies.
6. Warranties: Attorneys represent and warrant that Attorneys will perform all
Legal Services identified in this Agreement in a professional manner and in accordance with
all professional standards and laws. The provisions of this section shall survive the
expiration or termination of this Agreement.
7. Notices: Any notice required under this Agreement will be in writing,
addressed to the appropriate party at the address which appears below (as modified in
writing from time to time by such party), and given personally, by registered or certified mail,
return receipt requested, or by nationally recognized overnight courier service. Time period
for notices shall be deemed to have commenced upon the date of receipt. Email and
PAGE 4 OF 9
telephone may be used for purposes of administering the Agreement, but should not be
used to give any formal notice required by the Agreement.
CITY OF RENTON
Alex Tuttle
1055 South Grady Way
Renton, WA 98057
Phone: (425) 430-6492
atuttle@rentonwa.gov
legaladmin@rentonwa.gov
ATTORNEYS
Nicholas M. Clabbers
Kaplan Kirsch LLP
1675 Broadway, Suite 2300
Denver, CO 80202
Phone: 303-825-7000
nclabbers@kaplankirsch.com
8. Termination:
A. Each Party has the right to terminate this agreement subject to
applicable notice requirements and other restrictions set forth in the court rules or
applicable law. In the event of such termination, all finished or unfinished documents, data,
studies, worksheets, models and reports, or other material prepared by the Attorneys
pursuant to this Agreement shall be submitted to the City.
B. In the event this Agreement is terminated by the City, Attorneys shall
be entitled to payment for all hours worked to the effective date of termination, less all
payments previously made. This provision shall not prevent the City from seeking any legal
remedies it may have for the violation or nonperformance of any of the provisions of this
Agreement and such charges due to the City shall be deducted from the final payment due
the Attorneys. No payment shall be made by the City for any expenses incurred or work done
following the effective date of termination unless authorized in writing by the City.
9. Record Maintenance: The Attorneys shall maintain accounts and records,
which properly reflect all direct and indirect costs expended and Legal Services provided in
the performance of this Agreement and retain such records for as long as may be required
by applicable Washington State records retention laws, but in any event no less than ten
years after the termination of this Agreement. The Attorneys agree to provide access to and
copies of any records related to this Agreement as required by the City to audit expenditures
and charges and/or to comply with the Washington State Public Records Act (Chapter 42.56
RCW). The provisions of this section shall survive the expiration or termination of this
Agreement.
10. Public Records Compliance:
A. Stipulations and Agreements. Attorneys shall familiarize themselves
with the Public Records Act and shall consider the City’s obligations thereunder when
considering strategy or entering stipulated motions or orders on behalf of the City.
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Attorneys shall not, without the informed consent of the City, enter a stipulation or
agreement on behalf of the City which contains a confidentiality provision.Any such
agreement must be signed by a representative of the City to be binding upon the City.
B. Cooperation. To the full extent the City determines necessary to
comply with the Washington State Public Records Act, Attorneys shall make a due diligent
search of all records in their possession or control relating to this Agreement and the Legal
Services, including, but not limited to, e-mail, correspondence, notes, saved telephone
messages, recordings, photos, or drawings and provide them to the City for production.
Attorneys shall produce for distribution any and all records responsive to the Public Records
Act request in a timely manner, unless those records are protected by court order.
C. Indemnification. Attorneysshall indemnify, defend, and hold harmless
the City for all costs, including attorneys’ fees, attendant to any claim or litigation related to
a Public Records Act request (i) for which Attorneys have responsive records and for which
Attorneys have withheld records or information contained therein, or not provided them to
the City in a timely manner; and (ii) arising from or related to records subject to a
confidentiality provision entered in violation of subsection A of this section.
D. The provisions of this section shall survive the expiration or
termination of this Agreement.
11. Independent Contractor Relationship:
A. The Attorneys are retained by the City only for the purposes and to the
extent set forth in this Agreement. The nature of the relationship between the Attorneysand
the City during the period of the Legal Services shall be that of an independent contractor,
not employee. The Attorneys, not the City, shall have the power to control and direct the
details, manner or means of Legal Services within the parameters of applicable laws and
rules of professional responsibility.
B. The City shall not be responsible for withholding or otherwise
deducting federal income tax or Social Security or contributing to the State Industrial
Insurance Program, or otherwise assuming the duties of an employer with respect to
Attorneys or any employee of the Attorneys.
C. Attorneys shall furnish all tools and materials necessary to perform the
Legal Services except to the extent specifically agreed herein.
D. In the event special training, licensing, or certification is required for
Attorneys to provide Legal Services they will acquire or maintain such at their own expense
and, if Attorneys employ or otherwise assign the responsibility to perform the Legal Services,
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said employee or assignee will acquire and or maintain such training, licensing, or
certification.
E. Attorneys are responsible for their own insurance, including, but not
limited to health insurance, and for their own Worker’s Compensation coverage as well as
that for any persons employed by the Attorneys.
12. Hold Harmless: The Attorneys agree to release, indemnify, defend, and hold
harmless the City, elected officials, employees, officers, representatives, and volunteers
from any and all claims, demands, actions, suits, causes of action, arbitrations, mediations,
proceedings, judgments, awards, injuries, damages, liabilities, taxes, losses, fines, fees,
penalties, expenses, attorney’s or attorneys’ fees, costs, and/or litigation expenses to or by
any and all persons or entities, arising from, resulting from, or related to the negligent acts,
errors or omissions of the Attorneys in their performance of this Agreement or a breach of
this Agreement by Attorneys, except for that portion of the claims caused by the City’s sole
negligence.
13. Gifts and Conflicts: In compliance with the City’s Code of Ethics and state
law, the Attorneys shall not give a gift of any kind to City employees or officials. Attorneys
also confirm that Attorneys do not have a business interest or a close family relationship
with any City officer or employee who was, is, or will be involved in selecting the Attorneys,
negotiating or administering this Agreement, or evaluating the Attorneys’ performance of the
Legal Services.
14. Insurance: Attorneys shall secure and maintain:
A. Professional Liability, Errors and Omissions coverage with minimum
limits of $1,000,000 per occurrence and shall provide a certificate of insurance to the City
before providing Legal Services;
B. Workers’ compensation coverage, as required by the Industrial
Insurance laws of the State of Washington; and
C. Commercial Automobile Liability for owned, leased, hired or non-
owned, leased, hired or non-owned, with minimum limits of $1,000,000 per occurrence
combined single limit, if there will be any use of Attorneys’ vehicles on the City’s Premises
by or on behalf of the City, beyond normal commutes.
D. Attorneys shall provide the City with written notice of any policy
cancellation, within two (2) business days of their receipt of such notice.
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15. Successors and Assigns: Neither the City nor the Attorneys shall assign,
transfer or encumber any rights, duties or interests accruing from this Agreement without
the written consent of the other.
16. Discrimination Prohibited: Attorneyagrees as follows:
A. Attorneys, and Attorneys’ agents, employees, representatives, and
volunteers with regard to the Legal Services performed or to be performed under this
Agreement, shall not discriminate on the basis of race, color, sex, religion, nationality,
creed, marital status, sexual orientation or preference, age (except minimum age and
retirement provisions), honorably discharged veteran or military status, or the presence of
any sensory, mental or physical handicap, unless based upon a bona fide occupational
qualification in relationship to hiring and employment, in employment or application for
employment, the administration of the delivery of Legal Services or any other benefits under
this Agreement, or procurement of materials or supplies.
B. The Attorneys will take affirmative action to ensure that applicants are
consideredand that employees are treated during employment without regard to their race,
creed, color, national origin, sex, age, sexual orientation, physical, sensory or mental
handicaps, or marital status. Such action shall include, but not be limited to the following
employment, upgrading, demotion or transfer, recruitment or recruitment advertising, layoff
or termination, rates of pay or other forms of compensation and selection for training.
C. If the Attorneys fail to comply with any of this Agreement’s non-
discrimination provisions, the City shall have the right, at its option, to cancel the Agreement
in whole or in part.
D. The Attorneys are charged with knowledge of and compliance with all
federal, state and local laws and regulations that may affect the satisfactory completion of
the project, which includes but is not limited to fair labor laws, worker's compensation, and
Title VI of the Federal Civil Rights Act of 1964, and will comply with City of Renton Council
Resolution Number 4085.
17. Miscellaneous:
A. Approval Authority. Each individual executing this Agreement on
behalf of a Party hereto represents and warrants that the individual is duly authorized to
execute and deliver this Agreement on behalf of the Party.
B. General Administration and Management. The City’s contract
managers are identified in Section 6 above. In providing Legal Services, Attorneys shall
coordinate with the City’s contract manager or the manager’s designee.
EXHIBIT A
PAGE 8 OF 9
C. Amendment and Modification. This Agreement may be amended only
by an instrument in writing, duly executed by both Parties.
D. Conflicts. Any exhibits/attachments to this Agreement are
incorporated by reference only to the extent of the purpose for which they are referenced
within this Agreement. Unless otherwise expressly agreed, tothe extent an exhibit conflicts
with the terms in the body of this Agreement or contains terms that are extraneous to the
purpose for which the exhibit is referenced, the terms in the body of this Agreement shall
prevail and the extraneous terms shall not be incorporated herein.
E. Governing Law. This Agreement shall be made in and shall be governed
by and interpreted in accordance with the laws of the State of Washington and the City of
Renton. Attorneys and all of the Attorneys’ employees shall perform the Legal Services in
accordance with all applicable federal, state, county and city laws, codes and ordinances.
F. Joint Drafting Effort. This Agreement shall be considered for all
purposes as prepared by the joint efforts of the Parties and shall not be construed against
one party or the other as a result of the preparation, substitution, submission or other event
of negotiation, drafting or execution.
G. Jurisdiction and Venue. Any lawsuit or legal action brought by any party
to enforce or interpret this Agreement or any of its terms or covenants shall be brought in
the King County Superior Court for the State of Washington at the Maleng Regional Justice
Center in Kent, King County, Washington, or its replacement or successor. Attorneys
hereby expressly consents to the personal and exclusive jurisdiction and venue of such
court even if Attorneys is a foreign corporation not registered with the State of Washington.
H. Severability. A court of competent jurisdiction’s determination that
any provision or part of this Agreement is illegal or unenforceable shall not cancel or
invalidate the remainder of this Agreement, which shall remain in full force and effect.
I. Sole and Entire Agreement. This Agreement contains the entire
agreement of the Parties and any representations or understandings, whether oral or
written, not incorporated are excluded.
J. Time is of the Essence. Time is of the essence of this Agreement and
each and all of its provisions in which performance is a factor. Adherence to completion
dates set forth in the description of the Legal Services is essential to the Attorneys’s
performance of this Agreement.
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K. Third-Party Beneficiaries. Nothing in this Agreement is intended to, nor
shall be construed to give any rights or benefits in the Agreement to anyone other than the
Parties, and all duties and responsibilities undertaken pursuant to this Agreement will be for
the sole and exclusive benefit of the Parties and no one else.
L. Binding Effect. The Parties each bind themselves, their partners,
successors, assigns, and legal representatives to the other party to this Agreement, and to
the partners, successors, assigns, and legal representatives of such other party with
respect to all covenants of the Agreement.
M. Waivers. All waivers shall be in writing and signed by the waiving party.
Either party’s failure to enforce any provision of this Agreement shall not be a waiver and
shall not prevent either the City or Attorneys from enforcing that provision or any other
provision of this Agreement in the future. Waiver of breach of any provision of this Agreement
shall not be deemed to be a waiver of any prior or subsequent breach unless it is expressly
waived in writing.
N. Counterparts. The Parties may execute this Agreement in any number
of counterparts, each of which shall constitute an original, and all of which will together
constitute this one Agreement.
IN WITNESS WHEREOF, the Parties have voluntarily entered into this Agreement as
of the date last signed by the Parties below.
CITY OF RENTON
By:_____________________________
ATTORNEYS
By:____________________________
Martin Pastucha
Public Works Administrator
Nicholas M. Clabbers,Partner
Kaplan Kirsch LLP
_____________________________
Date
_____________________________
Date
Approved as to Legal Form
By:Approved by Alex Tuttle via
email 7/8/2025
Alex Tuttle
Senior Assistant City
Attorney
________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________:__________________________
7/9/2025
May 14, 2025
VIA E-MAIL TO ATUTTLE@RENTONWA.GOV
Alex Tuttle, Senior Assistant City Attorney
City of Renton, WA
1055 South Grady Way
Renton, WA 98057
Re: Engagement for Legal Services
Dear Mr. Tuttle:
We are very pleased that City of Renton City
to advise the City with regard to federal regulatory compliance at the Renton Municipal Airport.
This letter sets forth the terms under which the Firm will represent the City on this matter and any
other matters as directed by the City.
While we are reluctant to be overly formal, we have found that a detailed retainer letter is the best
way to satisfy our ethical obligations and to be sure that obligations are clearly set
forth in writing.
While the City was previously a client of the Firm, the effective date of our renewed representation
is May 14, 2025. I will be the partner-in-charge of this engagement and will be the contact person
for the Firm on this matter. At any time during our representation, you and your colleagues should
always feel free to contact me or any other Firm partner if you have any questions or concerns
about our work on your behalf. Our Robert W. Randall, is always
available in the event you have questions about our representation.
Scope of Our Representation . The City is engaging the Firm to advise on matters related to
federal regulatory compliance at the Renton Municipal Airport and other matters to which we may
jointly agree in writing. The scope of our representation is limited to these matters.
Attorneys within the Firm are licensed to practice law before the U.S. Supreme Court, most federal
appellate and many federal district courts, as well the highest court in many states. To the extent
that you seek advice with respect to states where Firm attorneys are not licensed, we will provide
advice in a manner consistent with the rules of professional conduct applicable to the practice of
law in that state.
Opinions on Likely Outcomes. Either at the commencement or during the course of our
representation, attorneys in the Firm may express opinions or conclusions concerning the likely
EXHIBIT A
Alex Tuttle, Senior Assistant City Attorney
May 14, 2025
Page 2
outcome of the matters or various courses of action and the results that might be anticipated. We
trust that you understand that, while we will always endeavor to give you candid and accurate
assessments, any such statements will be an expression of our opinion based on information
available to us at the time and are not a promise or guarantee.
Fees and Charges. The Firm will charge for its services according to the fees set out herein. I
will be the partner-in-charge of this matter but anticipate involvement by other attorneys, as
needed, in particular, Catherine M. van Heuven, Peter J. Kirsch, and Sarah E. Wilbanks. For
purposes of this engagement, Firm partners will be charged at $650 per hour, and Firm associates
at $450 per hour. The normal hourly rates for attorneys in the Firm range from $625 to $1,075 per
hour. Paralegal/law clerk rates are charged $200 per hour. The Firm charges fees in six-minute
(1/10 hour) increments. These rates will be effective until at least the end of this calendar year.
The Firm annually evaluates its rates and will notify you in advance of any anticipated changes in
rates.
In addition to the hourly fee for services, the Firm will charge you for all necessary and incidental
out-of-pocket expenses, including, but not limited to, travel costs, office expenses, computerized
legal research, court reporting services, and court or other filing fees. We do not generally charge
for routine photocopying and long-distance telephone or cell phone calls but do charge for
especially large copying jobs, color copies and hosting conference calls, in some instances. Out-
of-pocket expenses are charged at our actual cost. Please let us know if you have any special
requirements for the expenditure or reporting of expenses.
Invoices
amounts billed for particular matters during the period covered by the invoice. Unless you request
otherwise, our invoices will contain
We can, however, prepare that invoice in any format that meets your needs. We urge you to raise
any questions regarding our invoices as soon as they arise so that we can resolve any problems
promptly. We require that the City pay our fees promptly on a monthly basis. We consider any
invoice more than 30 days old to be overdue. If the City does not inform the Firm, in writing, of
any questions or concerns with respect to the charges contained on an invoice within 30 days of
receipt, the Firm will assume and the City agrees that such charges are acceptable to the City. The
Firm reserves the right to charge interest of one percent per month on any outstanding amounts on
invoices over 60 days old.
Conflicts Evaluation. In accordance with the applicable ethical rules, we have confirmed that we
have no current actual conflicts between the City and any Firm clients. Further, we are not aware
of any potential conflicts. As you are aware, the Firm represents a number of public sector and
private sector clients in the airport industry. We cannot foreclose the possibility that, at some time
in the future, any existing or future Firm client may be adverse to the City on matters completely
unrelated to this engagement. It is also possible that an existing Firm client is currently adverse to
the City on a matter of which we are unaware or in which we have no involvement. The City
understands and agrees that the Firm may represent new and existing clients in any matter that is
Alex Tuttle, Senior Assistant City Attorney
May 14, 2025
Page 3
not substantially related to our work for the City even if the interest of such other clients may be
directly adverse to the City or to any entity or person related to the City, with one exception: This
prospective consent to conflicting representation will, of course, not apply to any matter where, as
a result of our work for the City, we have obtained sensitive, proprietary, or otherwise confidential
information that could be used by such other clients to the material disadvantage of the City.
Should we be involved in other matters for the City, the conflict evaluation will be done at that
time on a case-by-case basis.
Termination of Our Engagement. Upon completion or termination of our representation on the
matters described above, the attorney-client relationship will end unless the City and the Firm have
agreed to a continuation with respect to other matters. The City has the right, at any time, to
terminate our services and representation upon written notice to the Firm. We reserve the right to
withdraw from our representation if, among other things, you fail to honor the terms of this
engagement letter, you fail to cooperate or follow our advice on a material matter or any fact or
circumstance (including any conflict of interest with another client) that would, in our view, render
our continuing representation unlawful or unethical. If we elect to withdraw, you will take all
steps necessary to free us of any obligation to perform further, including the execution of any
documents necessary to complete our withdrawal. No termination of our representation by the
City or the Firm will relieve you of your obligations under the terms of our engagement to pay for
services rendered or for costs or expenses paid or incurred on your behalf. In the unusual event
that a court of competent jurisdiction refuses to permit us to withdraw upon termination, you would
remain responsible for fees and costs. In the event we are compelled to intervene in a pending
lawsuit or initiate any proceeding in order to recover any amount due under the terms of our
engagement, the prevailing party is entitled to be reimbursed for any and all reasonable attorneys
fees, court costs, and expenses incurred in such proceeding.
Entire Understanding of Terms of Our Representation. This engagement letter constitutes our
entire understanding and agreement with respect to the terms of our engagement and supersedes
any prior understandings and agreements, written or oral, regarding representation on this matter.
This engagement letter also supersedes the previous engagement agreement between the City and
the Firm. If any provision of our engagement letter is held by a court of competent jurisdiction to
be invalid, void, or unenforceable, the remainder of the provisions shall remain in full force and
effect. This engagement letter may only be amended in writing by the Firm and the City.
We look forward to working with you and your colleagues on this matter, and we look forward to
a mutually satisfactory relationship. Thank you again for your interest in engaging the Firm.
Alex Tuttle, Senior Assistant City Attorney
May 14, 2025
Page 4
Sincerely,
By:
Nicholas M. Clabbers