HomeMy WebLinkAboutcoa.lu.ex.N Mill St-Morse&Pabst.1974
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EXEMPTION FROM SUBDIVISION
WHEREAS, the Muncipal Code of the City of Aspen, more
specifically Section 20-10(b) thereof, provides that
"Following receipt of a recommendation from
the Planning Commission, City Council may
exempt a particular division of land from the
definition of a subdivision set forth in
Section 20-2(a) when, in the judgment of
the City Council, such division of land
is not within the intent and purpose of
this Chapter 20", and
WHEREAS, EDWARD W. MORSE and HARALD PABST, have sub-
mitted an application for exemption pursuant to Section 20-10(b)
for the following tract consisting of approximately 58,000
square feet of land, more particularly described as:
A tract or parcel of land within the northwest
quarter of the southwest quarter of Section 7,
Township 10 South, Range 84 West, Sixth Principal
Meridian, at Aspen, in pitkin County, State of
Colorado, described as follows:
Commencing at the southeast corner of the northwest
quarter of the southwest quarter of Section 7,
Township 10 South, Range 84 West; thence North 89
degrees 32 minutes West along the south line of
said subdivision a distance of 184.4 feet; thence
North 53 degrees 35 minutes West 335 feet; thence
North 1 degree 15 minutes East 100 feet; thence
North 7 degrees 45 minutes West 217 feet to the
true point of beginning of the tract of land herein
conveyed; then South 82 degrees 15 minutes West
a distance of about 303.0 feet to a point 50 feet
easterly measured at right angles from the center
line of the track of the Aspen branch of The Denver
and Rio Grande Western Railroad Company; thence
southeasterly along the arc of a curve to left
having a radius of 668 feet a distance of 222.1
feet, said arc having a long chord 221.1 feet
in length with course South 24 degrees 08 minutes
East; thence South 71 degrees 50 minutes East
151 feet; thence North 18 degrees 10 minutes
East 240 feet; more or less; thence North 7
degrees 45 minutes West 63 feet to the point of
beginning, containing 1.33 acres, more or less,
and
WHEREAS, the application is made so as to permit convey-
ance of parcels of 6,000 square feet and 52,000 square feet
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to Edward E. Morse and Harald Pabst, respectively, following
dissolution of a joint venture entitled "Mill Street & Morse"
pursuant to Article of Dissolution dated September 15, 1970,
and
WHEREAS, the Aspen Planning and Zoning Commission
has recommended to the City Council the grant of this exemption
at its meeting held October 1, 1974, and such grant of exemption
was approved by the City Council at its meeting held October 15,
1974,
NOW, THEREFORE, there is hereby made this grant of
exemption from definition of subdivision (set forth in Section
20-2(a) of the Aspen Municipal Code) for the conveyance by
"Mill Street & Morse", a joint venture, to Edward E. Morse and
Harald Pabst of parcels of approximately 6,000 square feet and
52,000 square feet, respectively, from the tract of land herein-
above described, which grant of exemption is made under
Section 20-10(b) of the Municipal Code subsequent to recommenda-
tion of the Planning Commission and pursuant to a motion duly
made, seconded, and approved by the Aspen City Council on
October 15, 1974'__gg;.~f
Date,@j 16 I Wit! ~
t- ~--Stacy tandley III
Mayo ~~
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I, Lorraine Graves, duly appoint d and acting CittJ
Clerk, do hereby certify that the foregoing Exemption from
the Definition of Subdivision was approved by the Aspen City
Council at its regular meeting held Tuesday, October 15, 1974.
(Seal)
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\ _"/"""Lorraine Grave
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_!.!gular.. M~~t~n_g
Asp~ri City Council
October 15, 1974
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Council Walls moved to adopt Resolution $ 33, Series of 1974, Seconded by Council-
woman Markalunas. All in favor, motion carried.
RESOLUTION # 34, SERIES OF 1974
Councilman Walls moved to read Resolution # 34, Series of 1974. Seconded by
Councilwoman Markalunas. All in favor, motion carried.
RESOLUTION #34
SERIES OF 1974
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WHEREAS, on advice of coun3el the City Council has determined that re-
entry as a party protestant in that litigation cOIIUIlonly known as the "Twin Lakes"
litigation is appropriate based on the new information supplied to the City's
advisors on this matter,
NOW, TIlEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF TIlE CITY OF AS PEN,
COLORADO ,
1. That it does repeal its former directive to withdraw and direct
that the CitJ of Aspen be re-instated.as a party litigant in the following civil
actions:
a. In the Matter of the Application for Change of Water Rights of the
Twin Lakes Reservoir and Canal Company, Case Number W-1901, Water
Division No.5; and
b. In the Matter of the Application for Water Rights of Twin Lakes
Reservoir and Canal Company for the New York Collection Canal Supplement
for the Independence Pass Trans-Mountain Diversion System, Case
Number W-1869, Water Division No.5.
2. That the City Attorney, at her convenience, so advise Vranesch and
Musick, attorneys at law.
was read in full by the City Attorney.
Councilwoman Markalunas moved to adopt Resolution # 34, Series of 1974. Seconded
by Councilman Walls. All in favor, motion carried.
ORDINANCE #48, SERIES OF 1974
Councilman Breasted moved to read Ordinance #48, Series of 1974 on first reading.
Seconded by Councilman Walls. All in favor, motion carried.>
ORDINANCE #48, SERIES OF 1974, AN ORDINANCE PROVIDING FOR TIlE ELECTION OF TIlE
SUCCESSOR OR SUCCESSORS TO A RECALLED COUNCII}~N OR MAYOR AT TIlE TIME OF SUBMISSION
OF TIlE QUESTION OF RECALL ALLAS PERMITtED BY TIlE RECENT AMENDMENT OF SECTION 3.8 OF TIlE
ASPEN MUNICIPAL CHARTER was read by title by the City Clerk.
Councilman Walls.moved to adopt Ordinance #48, Series of 1974 on first reading.
Seconded by Councilman Behrendt. Roll call vote - Council members Wails aye;
Behrendt aye; Brea sted aye; Markalunas aye; Pedersen aye; Mayor Standley ayea
. Motion carried.
ORDINANCE #49, SERIES OF 1974
City/County Planner Stanford suggest Council schedule an additional public hearing
for citizen imput.
Councilman Walls moved to schedule a public hearing on November 11th for citizen
imput on Ordinance #49. Seconded by Councilman Breasted.
Councilman Walls request all architects be notified of this meeting.
All in favor, motion carried.
MAYOR'S DEEDS
Co~ncilwoman Pedersen moved to authorize the Mayor and City Clerk to execute deeds
to Robert and Judith Smith and a Iso deed .to Grace E. Huffman as presented by the
City Attorney. Seconded by Councilman W.lls. All in favor, motion carried.
MILL STREET & MORSE SUBDIVISION EXEMPTION
City Attorney submitted to Council the complete file. She further stated the
question before Council is do you feel the intent of the subdivision regulations
are being evaded by this request. P & Z felt it is not in this case.
Councilman Walls moved to approve the subdivision exemption agreement as submitted.
Seconded by Councilwoman Markalunas. All in favor, motion carried..
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or:
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Water litig-
ation
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Ord .1,48
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Ord.#49 Historic
Overlay
Deeds
Pabst & Morse J
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TO:
FROM:
DATE:
RE:
John
MEMORANDUM
JOHN STANFORD, PLANNER
SANORA M. STULLER, CITY ATTORNEY
September 16, 1974
APPLICATION OF HAROLD PABST AND EDWARD MORSE
FOR EXEMPTION FROM SUBDIVISION REGULATION
Let me make two points initially before I go into the
merits of the application.
1. First, John Wendt's letter states that the joint
venture is governed by the Uniform Partnership
Act, Chapter 104, Article 1, of Colorado Revised
Statutes. This is in opposition to a line in
Section 4.1 of the Joint Venture Agreement where
the parties thereto state: "This agreement in
nowise shall limit the operation of either party
as an individual or in joint operations with
others and it is not the intention of the parties
hereto to form ~ partnership." -
2. Secondly, Mr. Wendt closes his letter by saying:
"It is understood and agreed that the
unimproved Pabst tract would be subject
to all of the applicable subdivision and
zoning regulations with respect to sub-
divisions, building and use."
I hope no one on the Commission will be misled by
the above so as to anticipate there will be compliance
with Chapter 20 without further parceling or
condominiumization. Mr. Pabst, in his affidavit,
makes clear that without such event occurring
Chapter 20 will not be satisfied. He says:
"I understand that the lands to which
I am entitled upon dissolution and winding
up of the joint venture are subject to the
zoning code, and if subdivided, to the
subdivision code.--
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Memorandum to
September 16,
Page Two
John Stanford
1974
Legal Issue
The basic issue is whether the joint venture, by quit-
claiming the two parcels to the respective joint ventures,
constitutes a subdivision of land and, if so, whether an
exemption to the requirements of Chapter 20, pursuant to
S20-10 is appropriate. I will not address the latter issue
as that is one to be dealt with by the Commission itself.
As for the former, the existing Section 20-2 provides in
part:
"(a) Subdivision. A subdivision or subdivided land
is defined as a tract of land which is divided
into two (2) or more lots, tracts, parcels, sites,
separate interests, . . ., interests in common
. . for the purpose, whether lmmediate or
future, or transfer of ownership, or for build-
ing or other development."
It is submitted that, without more, the creation of the joint
venture and transfer of the real estate into the venture
created an interest in common between Pabst and Morse, and
this event constituted a subdivision of land. However,
~the city might very well be estopped at this time (a
permit having been issued) to allege a violation of Chapter
20 and (2) I think the following continuation of subsection (a)
takes the transaction outside the definition of subdivision:
". . . Unless the method of land disposition is
adopted for the purpose of evading this definition,
the term subdivision as defined in this section
20-2(a) shall not apply to any of the following
divisions of land: . . . (6) The division of land
by the acquisition of an interest in land in the
name of a husband and wife or other persons in
joint tenancy or as tenants in common and any such
interest shall~e~eemed for:purposes of this
Section 20-2(a) as only one interest."
We have no evidence that the joint venturers intend by
their agreement to avoid the consequences of Chapter 20 (the
affidavits being to the contrary and the history of lack of
development of the whole parcel supporting this contention).
I do not agree with the policy that those taking as tenants
in common should be exempt, but that is the code as it stands
(the state regulations, county regulations, and new city
regulations having the identical language). The proviso
about intention to evade the effects of taking in such manner
is designed to deal with a situation like that described in
the California case of Pratt v Adams, 229 Cal. App. 2d 602,
40 Cal Rptr. 505. At that time you were permitted to divide
.
Memorandum to John Stanford
September 16, 1974
Page Three
a parcel into five tracts, but no more, without going through
subdivision. A married couple bought a large tract for the
purposes of developing it. They did not want to go through
subdivision regulation and they sold the tract to two couples
(themselves included) as joint tenants. These four sold
their interests to 12 others (themselves included) as joint
tenants. All then petitioned to have the land partitioned
among themselves, and when completed, each divided his or
her share into four lots and sold them off. The Court con-
sidered this an obvious attempt to avoid the Subdivision
Act and upheld the City's refusal of building permits.
Conclusion
There is one element in the above I cannot establish
to a certainty and that is that joint venturers hold the land
as technically tenants in common, but the attributes of
ownership are so close that I am not going to dispute the
point in the absence of statutory or common law to the
contrary.
All of the above is noted to support my conclusion that
the contention that the partitioning of the land under the
circumstances testified to by the applicants does not come
under subdivision review is a valid premise, and one that I
cannot dispute.
SMS:ksh
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WENDT Be KISTLER
LAWYERS
DRAW E R 8429
ASPEN, COLORADO 8161 1
JOHN A. F. WENDT, JR
BRUCE KISTLER
THE PROFESSIONAL BUILDING
TELEPHONE: 303-925-4505
August 27, 1974
Spencer Schiffer, Esq.
Chairman, City of Aspen
Planning and Zoning Commission
Aspen, Colorado
Re: Harald Pabst and Edward W. Morse, Jr.,
formerly d/b/a Mill Street & Morse, a
joint venture.
APPLICATION FOR EXEMPTION FROM THE
APPLICATION OF THE DEFINITION OF A
SUBDIVISION IN SECTION 20-2(a),
MUNICIPAL CODE OF THE CITY OF ASPEN,
COLORADO,
OR
IN THE ALTERNATIVE, EXCEPTION FROM
THE STRICT APPLICATION OF CHAPTER 20,
MUNICIPAL CODE OF THE CITY OF ASPEN,
COLORADO.
1.
LAND DESCRIPTION:
The
are described
on the survey
lands which are the sUbject of this application
in Exhibit "A", attached hereto and as shown
map shown as Exhibit "B", attached hereto.
2.
HISTORY:
A. On May 9, 1969, Harald Pabst purchased
the unimproved lands from Vesta Ione Cate and Helen Elizabeth
Herman of Grand Junction, Colorado.
B. On May 22, 1969, Messrs. Morse and Pabst
entered into a joint venture agreement affecting the lands.
A copy of this agreement is attached as Exhibit "e". Pursuant
to the agreement, Mr. Pabst conveyed the lands to "Mill
Street & Morse".
C. Mill Street & Morse obtained a building
permit in the Spring of 1970 and constructed the building
known as the "Mason & Morse House Care Building" during
the 1970 building season. It was occupied in the fall of 1970
upon its completion.
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August 27, 1974
Spencer Schiffer, Esq.
Page Two
D. Messrs. Pabst and Morse on September 15,
1970 entered into Articles of Dissolution of "Mill Street
& Morse". Pursuant to the terms of the joint venture
agreement, Reese Henry, C.P.A. was consulted with respect
to the distribution of assets (paragraph 2.6, p.3, of the
Joint Venture Agreement). A copy is attached as Exhibit "F".
E. The requisite quit claim deeds required
by paragraph 2.4 of the Articles of Dissolution were not
prepared or executed due to the" advertence and neglect
of counsel. However, the parties have, between themselves,
effectuated its provisions in that each party has treated
his respective interest as his own; ~.[., Mr. Morse has used
the building for the operation of House Care. Mr. Pabst
leased his portion to the City of Aspen for the use of the
car impound lot.
3. APPLICABLE LAW:
A. C.R.S. 1963, Cha~ter 104, Article 1,
"Uniform Partnership Law". The JOInt venture agreement is
governed by the provIsIons of this Article. Accordingly,
application can be made to Court for dissolution pursuant
to 104-l-32(g).
B. S20-2(a)(1) Municiaal Code of the City
of As~en, Colorado provides that the efinition of a sub-
dIvisIon shall not apply to "the division of land by order
of any court in this state or by operation of law."
(emphasis added) It is the applicants' positIon that the
dissolution of a joint venture (partnership) with its
attendant winding up qualifies as an "operation of law".
It appears illogical to require that the parties resort to
a judicial decree in order to qualify for the exemption.
C. In the event that the Commission rejects the
applicants' claim for exemption, the applicants pray for an
exception pursuant to Section 20-10 of the Aspen Code.
Applicants submit that undue hardship would result from strict
compliance with the requirements and other provisions of
Chapter 20. Each applicant has a substantial property right
which cannot be preserved and enjoyed individually; granting
an exception will not be detrimental to the public welfare
or injurious to the property in the area in which the subject
property is located.
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August 27, 1974
Spencer Schiffer, Esq.
Page Three
4. NO INTENTION TO EVADE:
Counsel states that at no time in the chronology
of the 1969 and 1970 events was there any intention to evade
the application of Chapter 20 of the Code. Each of the
applicants make this statement in their affidavits attached
hereto as Exhibits "D" and "E".
5. END RESULT:
In the event that the relief sought is granted the
end result will be the division of the lands into a tract
of 6,000 square feet, more or less, and a tract of
approximately 52,000 square feet, with ownership of the
6,000 square foot tract which is improved vested in Edward
W. Morse, Jr. and the unimproved 52,000 square feet vested
in Harald Pabst.
No additional improvements, sUbdivision, etc. are
possible upon the Morse tract.
It is understood and agreed that the unimproved
Pabst tract would be subject to all of the applicable sub-
division and zoning regulations with respect to sUbdivision,
building and use.
Respectfully submitted,
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John A.F. Wendt
Attorney for the Applicants
cc: Ms. Sandra Stuller, City Attorney
The City of Aspen Planning Department
JAFW/sf
August 27, 1974
Spencer Schiffer, Esq.
Page Four
VERIFICATION
STATE OF COLORADO
ss.
County of Pitkin
Edward W. Morse, Jr. and Harald Pabst, being
first duly sworn upon their oaths, say that each of them
has read the foregoing Application, knows the contents
thereof and that the matters stated therein are true.
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Harald Pabst
Subscribed and sworn to before me this ~~ay
of August, 1974, by Edward W. Morse, Jr. and Harald Pabst.
Witness my hand and offical seal.
My commission expires: .;2-/,,1-')7
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Nota Public
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EXHIBIT "A"
A tract or parcel of land within the northwest quarter of the
southwest quarter of Section 7., Township 10 South, Range 84 West,
.Sixth Principal Meridian, at Aspen, in Pitkin County, State of
Colorado, described as follows:
Commencing at the southeast corner of the northwest quarter of
the southwest quarter of Section 7, Township 10 South, Range 84
West; thence North 89 degrees 32 minutes West along the south line
of said subdivision a distance of 184.4 feet; thence North 53
degrees 35 minutes W~st 335 feet; thence North 1 degree 15
minutes East 100 feet; thence North 7 degrees 45 minutes West 217
feet-to the true point of beginning of the tract of land herein
conveyed; thence South 82 degrees 15 minutes West a distance of
about 303.0 feet to a point 50 feet easterly measured at right
angles from the center line of the track of the Aspen branch of
The Denver and Rio Grande Western Railroad Company; .thence
southeasterly along the arc of a curve to left having a radius of
668 feet a distance of 222.1 feet, said arc having a long chord
221.1 feet in length with course South 24 degrees 08 minutes
East; thence South 71 degrees 50 minutes East 151 feet; thence
North 18 degrees 10 minutes East 240 feet, more or less; thence
North 7 degrees 45 minutes West 63 feet to the point of beginning,
containing 1.33 acres, more or less.
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EXHIBIT "c"
JOINT VENTURE AGREEMEN'T
THIS JOINT VENTURE AGREEMEN'T made and entered into by
and between EDWARD W. MORSE (hereafter referred to as "Morse")
and HARII.LD PABST (hereafter referred to as "Pabst"), both of
Pitkin County, Colorado, WITNESSETH:
I
RECITALS
1.1 Property: The real property which is the subject
of this agreement is approximately 58,000 square feet of land
described as follows:
A tract or parcel of land within the northwest
quarter of the southwest quarter of Section 7,
Township 10 South, Range 84 West, Sixth Princi-
pal Meridian, at Aspen, in Pitkin County, State
of Colorado, described as follows:
Commencing at the southeast corner of the north-
west quarter of the southwest quarter of Section
7, Township 10 South, Range 84 West; thence North
89 degrees 32 minutes West along the south line
of said subdivision a distance of 184.4 feet;
thence North 53 degrees 35 minutes West 335 feet;
thence North 1 degree 15 minutes East 100 feet;
thence North 7 degrees 45 minutes ~est 217 feet
to the true point of beginning of the tract of
land herein conveyed; thence South 82 degrees 15
minutes West a distance of about 303.0 feet to a
point 50 feet easterly measured at right angles
from the center line of the track of the Aspen
branch of The Denver and Rio ~rande Western Rail-
road Company; thence southeasterly along the arc
of a curve to left having a radius of 668 feet a
distance of 222.1 feet, said arc having a long
chord 221.1 feet in length with course South 24
degrees 08 minutes East; thence South 71 degrees
50 minutes East 151 feet; thence North 18 degrees
10 minutes East 240 feet, more or less;thence
North 7 degrees 45 minutes West 63 feet to the
point of beginning, containing 1.33 acres, more
or less.
Hereafter, for convenience, the above-described real property may
be referred to as the "property" or the "lands".
1.2 Ownership: The lands are owned by Pabst but con-
currently with the execution of this Agreement Pabst shall convey
the lands by special warranty deed to the joint venture.
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1.3 Purpose: The parties desire to and do enter into
this joint venture for the purpose of planning for (a) the
orderly use of the lands whether by way of sale to third parties
and/or ground lease; and (b) such business future for the lands
as will realize the maximum return on the property consonant with
the best interests of the parties.
1.4 Consideration: The consideration for this agree-
ment shall be the benefits each party shall derive from the
performance of its covenants and other good and valuable con-
sideration, the receipt of which is acknowledged.
II
GENERAL PROVISIONS
2.1 Joint Venture Name: This joint venture shall be
entitled" Mill Street & Morse " and may operate under
such name to facilitate the carrying out of the purpose of the
joint venture.
2.2 Term: The joint venture shall be for a term of
ten (10) years unless sooner terminated by (a) sale of the real
property to a third party; or (b) mutual consent of the parties;
or (c) death, bankruptcy or insanity of either party; or (d) sale
of one party's interest to the other party pursuant to paragraph
2.8.
,
2.3 Initial Contribution: The initial contribution
of each party is as follows:
a. Pabst - the lands at an agreed value of $63,500.
b. Morse - services with respect to acquisition of
the lands and expertise in the field of
real estate sales and land management.
Division of Profits and Losses:
2.4
(a)
Profits and losses shall be determined according
to sound accounting principles but without regard to the initial
contributions of the parties as detailed in paragraph 2.3.
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(b) The profits and losses of the joint venture shall
be divided by the parties upon the following bases:
(1) Pabst - 32/58ths
(2) Morse - 26/58ths.
(c) Contributions of working capital and/or advances
to meet current expenses made by the parties subsequent to the
effective date of this agreement shall be made in the same ratio
as above specified in subparagraph (b) for the division of profits
or losses.
(d) Subsequent contributions and/or advances shall be
made only by mutual consent of the parties.
2.5 Lack of Authority of Individual Member: No party
to this agreement shall have any authority to bind or obligate
the joint venture for any sum whatsoever except in case of a
bona fide emergency affecting the joint venture property. Neither
shall either party create or impose any contractual or other
liability on the joint venture or the other party without written
consent of the other party first obtained.
Any third person, firm or corporation dealing with the
joint venture does so at its peril unless the transaction con-
templated is under one hundred dollars ($100.00) en toto or is
executed by both members of the joint venture or the sole member
,
of the joint venture dealing with the third party produces a
written, executed and acknowledged consent to the transaction
by the other member of the joint venture.
2.6 Winding Up: (a) Upon termination of the joint
venture for any reason, a certified public accountant (C.P.A.),
licensed in Colorado, shall be employed by the joint venture
to make an audit of the books, records and accounts of the
joint venture.
(b) Distribution to the parties
upon liquidation shall be in cash or in kind or in cash and in
kind as the C.P.A. making the audit pursuant to subparagraph
(a) shall recommend.
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(c) Winding up shall be accomplished
within six (6) months of the date of termination of the joint
venture.
2.7 Non-assignability of Interest: The interest of
each party shall be non-assignable by way of unconditional
transfer, except as provided in paragraph 2.8, but any profits
attributable to the party's interest may be assigned by way of
pledge or mortgage.
2.8 First Right of Refusal or Sale to Other Party:
(a) (1) In the event that one Ilarty has received
a bona fide offer from a third party for his interest; or (2)
the joint venture has received a bona fide offer for its property
and only one party desires to sell his interest or the joint
venture property, the non-selling party shall have a period of
ten (10) days (including Sundays) in which to elect to meet the
bona fide offer upon said offer's identical terms and conditions.
If the non-selling party fails to exercise his election in the
manner provided in paragraph b, then it shall be deemed con-
clusively that he does not desire to meet such bona fide offer.
Thereupon the selling party shall be free to sell and assign
his interest to such third party upon the exact same terms as
were contained in the offer. The joint venture will thereupon
,
be terminated and its affairs wound up. PROVIDED. HOWEVER, such
transfer may be set aside by the non-selling party if, in fact
the selling party closes the transaction upon different terms
than those specified in the offer.
(b) In the event that one of the parties desires
to sell his interest, then he shall give notice to the other
party of the terms and conditions under which he will sell.
The non-selling party shall have a period of thirty (30) days
in which to elect to buy the interest upon the terms and
conditions so specified. During such term the selling party
may not solicit offers from third parties. If the non-selling
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party does not elect to meet such terms and conditions then the
party desiring to sell may do so but the right of refusal set
forth in subparagraph (a) of this paragraph 2.8 shall become
applicable to any offer subsequently received by the third
party. If the party desiring to sell does not sell his interest
within six months of the date of the notice given under this
subparagraph (b) then the procedure outlined in this subparagraph
(b) shall, at the expiration of said six months period, once
more become effective.
(c) If a party desires to buyout the other
party's interest he shall give notice of that fact specifying
the purchase price, terms and conditions of the offer. The
non-selling party shall have thirty (30) days in which to accept
the offer. In the event that the offer is not accepted, then
the provisions of subparagraphs (a) and (b) of this paragraph
2.8 shall become effective with respect to the non-selling
party's interest.
III
ADMINISTRATIVE PROCEDURES
3.1 Meetings: Meetings of the joint venture shall be
held quarterly at the office of Mason & Morse Real Estate in
Aspen, Colorado or at any other agree a upon place on the first
Monday of April, July, October and January of each calendar
year. Special meetings may be called on three (3) days notice
by either party. Minutes shall be kept of the meetings.
3.2 Consent: Consent shall be unanimous with respect
to any joint venture matter as between the parties only. In
the event that the parties cannot agree, each party shall select
a representative and the two repre~entatives so selected shall
themselves select a third representative. The parties and the
three representatives shall then vote upon the matter and the
vote of the majority of those present shall govern.
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A quorum for voting when representatives have been
selected shall be four (4) persons.
In the event that either party refuses to select a
representative, then for purposes of resolving the deadlock
E. H. Deming, of Aspen, Colorado shall be Morse's repre-
sentative and John A.F. Wendt
of Aspen, Colorado shall be deemed
Pabst's representative.
The reasonable charges of the three representatives
shall be an expense of the joint venture.
3.3 Manager: The joint venture may select, from year
to year, a resident manager who may, or may not, be a member of
the joint venture.
The resident manager shall be responsible for the
maintenance of proper books, records and accounts and shall pre-
pare for the members a monthly itemized statement of income and
disbursements.
The resident manager shall have and perform administrative
and ministerial functions only. He may not incur an expenditure
in excess of one hundred dollars ($100.00) without the consent of
the joint venture.
3.4 Bank Account: The joint venture shall maintain
a checking account in its name at The Bank of Aspen, Aspen,
,
Colorado. All checks drawn on the checking account shall be
signed by both members of the joint venture.
3.5 Notices: All notices shall be in writing and sent
by certified U. S. mail. The effective date of the notice shall
be its postmarked date. Notices shall be addressed as follows:
Morse: Mr. Edward W. Morse
Box Q
Aspen, Colorado 81611
Pabst: Mr. Harald Pabst
Box 35
Aspen, Colorado 81611
or such other address as one party shall furnish the other in
writing, as contemplated by this paragraph 3.5
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IV
MISCELLANEOUS
4.1 Limitation of Joint Venturer's Operations: It
is the purpose of this agreement to limit the joint operations
of the parties hereto to the operation herein set forth. This
agreement in nowise shall limit the operations of either party
as an individual or in joint operations with others and it is
~--
not the intention of the parties hereto to form a partnership.
-'------"^,.._,, "' ....-._--~--, ~..~'"------~~._,'-'--_.'"....~'-_..-~,,~ -, -,.
4.2 Choice of Law:
In all matters relating to the
interpretation or enforcement of this agreement the laws of the
State of Colorado shall govern.
4.3 Attorney's Fees:
In the event that this agreement
or the matters contemplated by it become the subject of disagree-
ment and/or litigation, the party prevailing shall, as a part of
his settlement, award or judgment, be entitled to the award of
his reasonable attorney's fees.
4.4 No Oral Agreements: This agreement constitutes
the sole joint venture agreement between the parties and each
party represents that there is no oral agreement or represent-
ation upon which he is relying.
Any amendment to this agreement shall be in writing
and mutually consented to by the parties.
,
4.5 Section Headings: The section and paragraph
headings employed herein are for convenience only and in nowise
shall be construed as proscribing or enlarging the meaning of
any portion hereof.
4.6 Gender: Throughout this agreement the masculine,
feminine and neuter genders may be utilized interchangeably to
suit the sense of the expression.
4.7 Succession: This agreement shall extend to and
be binding upon the heirs, personal representatives, successors
and assigns of the parties hereto.
-7-
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ment is
4.8
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The effective date of this agree-
Effective
'2..2- ,
U, 1969.
Date:
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Harald Pa st
STATE OF COLORADO
)
) ss.
)
County of Pitkin
The foregoing instrument was acknowledged before me
this 11M day of ~( 1969 by Edward W. Morse and Harald
"
Pabst.
Witness my hand and official seal:
My commission expires:
fl,y Co.)lrr.i~.s;;:.!-, CX~:;-'~5 /A3r. 14, i'l'i.3 :
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t"Y'Y'----<'--
Ii~r
Notary Publl.c
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-8-
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EXHIBIT "D"
AFFIDAVIT OF EDWARD W. MORSE, JR.
STATE OF COLORADO
)
) ss.
)
County of pitkin
Edward W. Morse, Jr., being first duly sworn upon
his oath, says that:
1. He formed with Harald Pabst the joint venture
known as "Mill Street & Morse" for the development of the
1.33 acres of land on North Mill Street. This joint venture
was formed in the Spring of 1969.
2. During the balance of 1969, affiant and Mr.
Pabst had numerous discussions as to what to do with the
land. As a result of these discussions it was agreed that
the joint venture should build a building. on the lands to
be rented to House Care, Inc.
3. The House Care building was started in the
Spring of 1970 and completed in the fall of 1970.
4. During the summer of 1970 affiant and Mr.
Pabst continued their discussions of what use to make of
the balance of the land. There was no agreement so it was
decided that the joint venture should terminate and each
party go his separate way. Accordingly, the Articles of
Dissolution of Mill Street & Morse were executed by us.
For tax reasons the venture's C.P.A., Reese Henry, recommended
that upon dissoultion and winding up that the assets be
distributed in kind.
5. An appraisal of the assets determined that if
I were to receive the House Care Building and 6,000 square
feet of land, the minimum lot size, that would be equivalent
in value to 52,000 square feet of unimproved land.
.
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.....",
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(EXHIBIT "D" continued)
6. Since September 1970, I have treated as
my separate property the House Care Building with 6,000
quare feet of underlying land and regarded the balance of
the land as belonging to Mr. Pabst.
7. In the winter of 1974 we discovered that all
the land was still in the joint venture's name, ~.~.,
Mill Street & Morse.
8. At no time was it ever contemplated that the
joint venture would be formed and then dissolved for the
purpose of evading the impact of the City of Aspen's
subdivision regulations. When we entered into the joint
venture I feel certain that both Mr. Pabst and myself felt
that it would be a long-term, beneficial relationship.
Further affiant says not.
Subscribed and sworn to before me this 0'8~
day of August, 1974, by Edward W. Morse, Jr.
My commission expires: .;2 -/1./-77
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EXHIBIT "E"
AFFIDAVIT OF HARALD PABST
STATE OF COLORADO )
) ss.
County of Pitkin )
Harald Pabst being first duly sworn upon his
oath says that:
1. In the Spring of 1969, I bought approximately
1.33 acres of land on North Mill Street from two sisters,
Mrs. Cate and Mrs. Herman of Grand Junction, Colorado.
Edward W. (Wendy) Morse, Jr. and I had been friends for a
long time and I respected his real estate expertise. We
discussed my use of the lands and we decided to form a joint
venture whereby I would convey the lands to "Mill Street
& Morse" and Wendy would contribute his services.
2. During the balance of 1969, Mr. Morse and
I discussed various ideas for the lands. Wendy wanted to
build a building that would adequately house his House
Care operations and I agreed that the venture should do so.
3. I have never been a developer but rather an
investor. My practice has been to buy land, improved or
unimproved, and either hold it for a long term or resell it.
4. It appeared to me in the summer of 1970 that
it would be in my best interests, both tax-wise and
philosophically, not to be involved in any further development
of the Mill Street & Morse venture land. Accordingly, Mr.
Morse and I agreed to terminate our partnership in the
venture. Our accountant, Reese Henry, advised that
distribution of assets should be in kind in order to negate
any then present tax consequences. We signed Articles of
Dissolution in September 1970 and since that time have
regarded the land as partitioned.
~
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(EXHIBIT "E" continued)
5. In the winter of 1974 I received an offer to
sell my Mill Street land. At this time it was discovered
that title to the land was still in "Mill Street & Morse"
6. At no time did I or have I contemplated any
use of the joint venture as a vehicle for escape from the
force of the City's subdivision regulations. I understand
that the lands to which I am entitled upon dissolution and
winding up of the joint venture are subject to the zoning
code and, if subdivided, to the subdivision code.
Further affiant says not.
Subscribed and sworn to before me this ~8~
day of August, 1974, by Harald Pabst.
My commission expires: ~-/~-71
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Notary Publl.c
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EXHIBIT "F"
AHTICLES OF DISSOLUTION
of
Mill Street & Morse
THESE ARTICLES OF DISSOLUTION made and entered into by and
between HARi\LD PABST (hereafter referred to as "Pabst") and EDWARD W. MORSE
(hereafter referred to as "Morse"), WITNESSETH:
I
RECITALS
1. 1 Joint Venture: The parties hereto entered into a Joint Venture named
"lVIill Street & Morse'pursuant to a written agreement with effective date of ]\IIay 22, 1969.
~
1. 2 Joint Venture Property: The lands owned by Mill Street & Morse consist
of approximately 58,000 square feet of land which is described as follows:
Commencing at the southeast corner of the northwest quarter of
the southwest quarter of Section 7, Township 10 South, Range 84
West; thence North 89 degrees 32 minutes West along the south
line of said subdivision a distance of 184.4 feet; thence North 53
degrees 35 minutes West 335 feet; thence North 1 degree 15
minutes East 100 feet; thence North 7 degrees 45 minutes West
217 feet to the true point of beginning of the tract of land herein
conveyed; thence South 82 degrees 15 minutes West a distance of
about 303. 0 feet to a point 50 feet easterly measured at right
angles from the center line of the track of the Aspen branch of
the Denver and Rio Gra..'lde Western Railroad Company; thence
southeasterly along the arc of a curve to left having a radius of
668 feet a distance of 222.1 feet, saW arc having a long chord
,
221. 1 feet in length with course South 24 degrees 08 minu tes .
East; thence South 71 degrees 50 minutes East 151 feet; thence
North 18 degrees 10 minutes East 240 feet, more or less;
thence North 7 degrees 45 minutes West 63 feet to the point of
beginning, containing 1. 33 acres, more or less.
A commercial building was constructed by Mill Street & Morse on the land
during the summer of 1970, which will be ready for occupancy in late September, 1970.
1. 3 Oral Agreement to Dissolve: Pabst and Morse are the sole members
of the Joint Venture. Each has a2,Teed orally with the other that it would be in the best
interests of the Joint Venture and themselves to dissolve the Joint Venture a..'ld divide
the Joint Venture assets after making provision for any Joint Venture debts.
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1. 4 Consideration: The consideration for these Articles of Dissolution
shall be the performances of the covenants hereafter set forth and other cons ideration,
the sufficiency of which each party aclmowledges.
1. 5 C. P.A. 's Recommendations: Reese Hen/.ly, Public Accountant of
)'//l-
!di1
Aspen, Colorado, has been retained pursuant to paragraph 2.6 "Windin?;!:!E:' of the
Joint Venture Agreement. He has recommended distribution in kind of the Joint Venture
assets.
II
MECHANICS OF DISSOLUTION
2.1 Statement of Dissolution: The Joint Venture doing business as Mill
Street & Morse is terminated with effective date of September 15, 1970 and shall
proceed immediately to wind up its affairs.
2.2 Transfer of Property: The real property which constitutes the sole
assets of the Joint Venture shall be distributed to the parties as follows:
A. ~--Pabst shall receive 52,000 square feet of
~/
f(yJ
B. Morse.- Morse shall receive 6,000 square feet of the
~proved land from the land described in paragraph numbered 1. 2.
paragraph 1. 2 land, which distribution shall include the improvements
erected in 1970.
The parties agree that the distribution described in this paragraph 2.2
are equivalent in value to a 32/58th interest as to Pabst and a 26/58th interest as to
Morse.
2.3 Survey: The Joint Venture shall cause a survey to be made so as to
properly describe the 52,000 square feet of land to be received by Pabst and 6,000
square feet of improved land to be received by Morse. The results of said survey shall
be shown as an addendum to these Articles of Dissolution and become a part hereof by
this reference.
2.4 Deeds: The Joint Venture shall give its quit claim deeds to Pabst and
Morse. The Pabst lands may be referred to as Tract A and the Morse lands as Tract B
in the paragraph 2.3 addendwn.
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2.5 Payment of Indebtedness: The Joint Venture shall make provision for
the payment of any existing indebtedness as well as that which it will incur in effecting
dissolution including survey costs, accoWltir,g and legal fees. If contributions by the
parties become necessary to effectuate this paragraph 2.5, they shall be made pursuant
to paragraph 2.4 of the Joint Venture Agreement.
2.6 Dissolution Accomplished By: The winding-up requisite to accomplish
complete liquidation and dissolution shall be h.tlished by December 31, 1970.
2.7 Indemnification: Upon h'ansfer of this Joint Venture property pursuant
to liquidation, the parties each agree to indemnify and hold harmless the other for any
and all liability which may be incurred by reason of use of the property so transferred.
This indemnification does not extend to (a) liability incurred by the Joint Venture but
where third party redress is sought after liquidation is complete and (b) liability which
either party might incur by reason of the act of termination of the Joint Venture and
liquidation of its assets pursuant to these Articles.
III
MISCELLANEOUS
3.1 Choice of Law: In all matters relating to the interpretation or
enforcement of these Articles, the laws of the State of Colorado shall govern.
3.2 No Oral Agreements: These Articles supersede all previous oral
agreements between the parties. Each party represent that there is no oral agreement
,
or representation upon which he is relying.
Any amendment to these Articles shall be in writing and executed by both
parties.
3.3 Section Headings: The section and paragraph headings employed
herein are for convenience only and shall in nowise be employed as definitive of any
portion hereof.
3.4 Succession: This agreement shall extend to and be binding upon the
heirs, personal representatives, successors and assigns of the parties hereto.
-;}.
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3.5 Attorney's Fees: The provisions of paragraph 4.3 of the Joint Venture
Agreement shall be applicable.
3.6 Effective Date: The effective date of these Articles is September 15, 1970.
MILL STREET & MORSE
II
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Harold Pabst
by
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by
Edward W. M rse
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MEMORANDUM
TO:
MEMBERS OF THE CITY COUNCIL
FROM:
SANDRA M. STULLER, CITY ATTORNEY
DATE:
October 2, 1974
RE:
REQUEST FOR EXEMPTION FROM DEFINITION OF
SUBDIVISION
Harold Pabst and Edward W. Morse, formerly doing business
as "Mill Street & Morse", a joint venture, have applied for
an exemption from the definition of subdivision, which applica-
tion received a positive recommendation from the P & Z at
its meeting Tuesday, October 1st. The applicable code
provision is Section 20-10(b) which reads:
"Following receipt of a recommendation from the
planning commission, City Council may exempt a
particular division of land from the definition
of a subdivision set forth in Section 20-2(a)
when, in the judgment of the City Council, such
division is not within the intent and purpose
of Chapter ~ (subdivision regulations)."
The lands affected are those on which the House Care building
sits and east of that parcel to Mill Street, constituting
1.33 acres, approximately.
History
The history of the ownership of the tract is as follows:
A. On May 9, 1969, Harold Pabst purchased the unimproved
lands from Vesta Ione Cate and Helen Elizabeth Herman of Grand
Junction, Colorado.
B. On May 22, 1969, Messrs. Morse and Pabst entered
into a joint venture agreement affecting the lands. A copy
of this agreement is attached as Exhibit "Cu. Pursuant to
the agreement, Mr. Pabst conveyed the lands to "Mill Street
& Morse".
_ ,"o._"_,~~,_,..,__~~,_,,""~..,~_.~,,,_.,~~.._~_x,.____w_,_. '
Memorandum to City Council
October 2, 1974
Page Two
C. Mill Street & Morse obtained a building permit
in the spring of 1970 and constructed the building known
as the "Mason & Morse House Care Building" during the 1970
building season. It was occupied in the fall of 1970 upon
its completion.
D. Messrs. Pabst and Morse on September 15, 1970,
entered into Articles of Dissolution of "Mill Street & Morse".
Pursuant to the terms of the joint venture agreement, Reese
Henry, C.P.A. was consulted with respect to the distribution
of assets (paragraph 2.6, p.3, of the Joint Venture Agree-
ment). A copy is attached is Exhibit "F".
E. The requisite quit claim deeds required by para-
graph 2.4 of the Articles of Dissolution were not prepared
or executed due to the advertence and neglect of counsel.
However, the parties have, between themselves, effectuated
its provisions in that each party has treated his respective
interest as his own; e.g., Mr. Morse has used the building
for the operation of House Care. Mr. Pabst leased his portion
to the City of Aspen for the use of the car impound lot.
conclusion
Morse and Pabst insist that at no time in the chronology
of events of 1969 and 1970 was there any intention to evade
the application of Chapter 20 of the Code. Each of the appli-
cants makes this statement in his affidavit attached as
exhibits "D" and "E".
In the event the exemption sought is granted, the end
result will be the division of the land into a tract of
6,000 square feet, more or less, and a tract of approximately
52,000 square feet, with ownership of the 6,000 square feet
tract which is improved vested in Edward Morse and the
unimproved 52,000square feet vested in Harold Pabst.
No additional improvements are possible on the Morse
tract, and the applicants understand and agree that the
unimproved Pabst tract will remain subject to all of the
applicable subdivision and zoning regulations in the event
of future development in the tract.
Additional Attachments
In addition to the exhibits referred to above, there is
included my memo to John Stanford dated September 16, and an
"Exemption from Subdivison" for execution by Stacy for
recordation if the application for exemption is approved by
the city council.
SMS:ksh
TO:
FROM:
DATE:
RE:
John
.
.
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MEMORANDUM
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JOHN STANFORD, PLANNER
SANDRA M. STULLER, CITY ATTORNEY
September 16, 1974
APPLICATION OF HAROLD PABST AND EDWARD MORSE
FOR EXEMPTION FROM SUBDIVISION REGULATION
Let me make two points initially before I go into the
merits of the application.
1. First, John Wendt's letter states that the joint
venture is governed by the Uniform Partnership
Act, Chapter 104, Article 1, of Colorado Revised
Statutes. This is in opposition to a line in
Section 4.1 of the Joint Venture Agreement where
the parties thereto state) "This agreement in
nowise shall limit the operation of either party
as an individual or in joint operations with
others and it is not the intention of the parties
hereto to form a partnership." ---
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2. Secondly, Mr. Wendt closes his letter by saying:
"It is understood and agreed that the
unimproved Pabst tract would be subject
to all of the applicable subdivision and
zoning regulations with respect to sub-
divisions, building and use."
I hope no one on the Commission will be misled by
the above so as to anticipate there will be compliance
with Chapter 20 without further parceling or
condominiumization. Mr. Pabst, in his affidavit,
makes clear that without such event occurring
Chapter 20 will not be satisfied. He says:
"I understand that the lands to which
I am entitled upon dissolution and winding
up of the joint venture are subject to the
zoning code, and if subdivided, to the
subdivision code.--
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Memorandum to John Stanford
September 16, 1974
Page Two
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Legal Issue
The basic issue is whether the joint venture, by quit-
claiming the two parcels to the respective joint ventures,
constitutes a subdivision of land and, if so, whether an
exemption to the requirements of Chapter 20, pursuant to
S20-10 is appropriate, I will not address the latter issue
as that is one to be dealt with by the commission itself.
As for the former, the existing Section 20-2 provides in
part:
"(a) Subdivision. A subdivision or subdivided land
is defined as a tract of land which is divided'
into two (2) or more lots, tracts, parcels, sites,
separate interests, . . ., interests in common
. . . for the purpose, whether immediate or
future~r transfer of ownership, or for build-
ing ~ other development."
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It is submitted that, without more, the creation of the joint
venture and transfer of the real estate into the venture
created an interest in common between Pabst .and Morse, and
this event constituted a subdivision of land. However,
~the city might very well be estopped at this time (a
permit having been issued) to allege a violation of Chapter
20 and (2) I think the following continuation of subsection (a)
takes the transaction outside the definition of subdivision:
". . . Unless the method of land disposition is
adopted ~ the purpose of evading this definition,
the term subdivision as defined in this section
20-2(a) shall not apply to any of the following
divisions of iand: . . . (6) The division of land
by the acquisition of an interest in land in the
name of a husband and wife or other persons in
joint tenancy or as tenants in common and any such
interest shall~e~eemed for-Purposes of this
Section 20-2(a) as only one interest."
We have no evidence that the joint venturers intend by
their agreement to avoid the consequences of Chapter 20 (the
affidavits being to the contrary and the history of lack of
development of the whole parcel supporting this contention).
I do not agree with the policy that those taking as tenants
in common should be exempt, but that is the code as it stands
(the state regulations, county regulations, and new city
regulations having the identical language). The proviso
about intention to evade the effects of taking in such manner
is designed to deal with a situation like that described in
the California case of Pratt v Adams, 229 Cal. App. 2d 602,
40 Cal Rptr. 505. At that time you were permitted to divide
.
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Memorandum to John Stanford
September 16, 1974
Page Three
a parcel into five tracts, but no more, without going through
subdivision. A married couple bought a large tract for the
purposes of developing it. They did not want to go through
subdi,ision regulation and they sold the tract to two couples
(themselves included) as joint tenants. These four sold
their interests to 12 others (themselves included) as joint
tenants. All then petitioned to have the land partitioned
among themselves, and when completed, each divided his or
her share into four lots and sold them off. The Court con-
sidered this an obvious attempt to avoid the Subdivision
Act and upheld the city's refusal of building permits.
Conclusion
There is one element in the above I cannot establish
to a certainty and that is that joint venturers hold the land
as technically tenants in common, but the attributes of
ownership are so close that I am not going to dispute the
point in the absence of statutory or common law to the
contrary.
All of the above is noted to support my conclusion that
the contention that the partitioning of the land under the
circumstances testified to by the applicants does not come
under subdivision review is a valid premise, and one that I
cannot dispute.
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