Begg CorrespondenceMr Bob Babb
Public Works Director
City of Kalispell
Kalispell MT 59901
RE: City of Kalispell
Real Estate Development
Teton Terrace aka Esperanza
Dear Mr Babb,
October 29, 1996
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In regards to my conversation with you and David Hclst on 7-esday
October 22, 1996 pertaining to the above referenced subdivision I
have the following concerns.
1. Was the city and/or it's agents authorized to tressoass on our
property immediately to the west of Teton Terrace ?
2. Was the city and/or it's agents granted ,.permission to store
materials (i.e. pipes, gravel, asphalt, construction debris) or
equipment (i.e. trucks, pickups, excavators, trailers, trerlchers,
backhoes) on our property ?
3. Was the city given an easement to dig a drainage ditch on our
property ?
4. Was the city legally empowered to direct the drainage from their
real estate development onto our property ?
At your earliest convenience I would appreciate any information you
could provide which would address those concerns.
cc: Norb Donahue
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TETON TERRACE
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PORTA
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BLOCK 3, PORTA VILLA SUBDIVISION
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FOUND I" PIPE WITH
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2989ES' (SEE C.O.S.
NOV-20-11396 16.07 FPr'" THOKRS DEPN & HOSKINS
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111=vugh the Ragi"er oz the tubject prqand your tnutaal dw4ussion. the City is aware of
;iveral ew=bGIs ents onto the BM pro".
A.. - , I'll I I'll, M-W70
%■PiPz=t on the BM PrW", SaWon ConstructUm hm removed mxly all material, a little
gravel remains, graded 1he disturbed arem and seedm the distirbed aregs. Ille city, as Part &
our coatrazt with Sandon, requim the couaww to provide a release from the ovwm. the
ftg's-
W was comer to an existwg dUcil
west of the alley at Yellowstone Street. This diteb appftn to be on the lkgg propeity Dr hiatm.
DWwbed areas have ben gra&d arul w4ded,
nc a=a to Lot I of Porta Villa Numbor 2 is twias O-iing un dw Begg properEy. a
pfirift access. We an at dus time unaware of the owners mme.
Lastly, the westcrly portijm of tbr alley and drdbap clitch am eucroaQbing ()n tW pCgg
prDperty- Tte alley was dedicated as part of porta Villa. Th tha 1970's it was smveled, la the
1980's, we believe the City pavod 1he gravel alley. Wc uo unocttWn wbea tb* ditch ww
&rWedthe City cleaned and graded the ditch in 1994 and Sandon hin re-gradW the ditch for
the project.
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The City prVosft to resk" disturbed art" by grading and seeding. Because weeds and air
quality -are seriow County issues, the City will provide cale of ft am$ until July 1997 to
enmue gennirmflon of tho sced and a magle hffbiddc application for weed ico=l. Of eawse
the w= adjotnmg Tewn Terrue will remve t1to samc bmatment.
II
NOV-20-19% 16:07 FP"M THOMRS AN 2, HOSKINS TO 7597739 P,02
11* City is requesting an eas=ent fbr the drabuge ditch cuEstrurted from Teton Ten= to
Yellowone SL=L And sium d= drainage ditcb from dw Yellowstone to 2 Mile Drive is us;,f
fur draindgv fiviu Pvrta Vifla, dw City 16 mqucating an mwm= as wcU,
Plem review this proposal with the other ow=s. We took fbrward to wmMuS wit you
amicably rvwlvc the enauwhment to bab parties benefit.
TOTAL P.E42
Mr Glen Neier
City of Kalispell
P 0 Box 1997
Kalispell MT 59903-1997
RE: Teton Terrace Encroachment
Mr Neier,
Thank you for your reply to my letter of October 29, 1996. Almost one month had
passed since I first contacted Mr Babb about my concerns and I had not received
even an acknowledgement from the city that they were addressing these issues.
I would like to point out to you that I have incurred considerable expenses since
these problems were brought to my attention including the title company for easement
searches and deed searches, engineering fees, survey fees, attorney fees, and I have
taken over 25 hours of my time in meeting with the various parties involved.
You should know that in addition to Sandon Construction we also had Harp Line
Construction and Montana Power craws digging and trespassing on our property.
I did indeed talk to TD&H about their assertions that a segment of property might
exist to the east of our property line that for lack of a better term we have referred
to as the "mystery triangle."
In the event that we were to accept your proposal we would need proof that the
parcel actually exists, that the city owns it and that the city can deed that
ownership to us free and clear and with title insurance.
According to the measurements that we have taken as I understand your proposal we
would then own all or a portion of the city alley. We would then need to know
from the city what rights we would have concerning use of the triangle. As an
example would we be allowed to fence it ? Will the city pay for the necessary
title and legal work involved ?
In regards to the ditch Mr Neier you refer to the mutual benefit that would be derived
by granting the city an easement. Could you please elaborate as to what our benefit
would be to have a 4 foot deep, 12 foot wide, 600 foot long drainage ditch down the
east edge of our property ? In addition if we did accept the triangle would the
city build a bridge or some sort of access to get from the triangle to the property ?
Who would be responsible if a child got hurt in the ditch ? Would the city maintain
the ditch and keep out the debris that the neighbors are constantly dumping on the
property ?
1
I feel that since the city is in the development business that it is not
reasonable for me to have to contact all of the various agents employed
by the city to complete its development. That job belongs to someone
in the city.
Finally Mr Neier I would like to request a copy of the engineering plans
for Teton Terrace so that we can try to determine the volume of water
that you plan to run down the ditch.
Your earliest attention to this matter will be greatly appreciated.
December 10, 1996
Jerry Begg
220 Woodland Avenue
Kalispell, MT 59901
Re: Teton Terrace
Dear Mr. Begg:
Your letter of October 29, 1996 has been referred to this office for a reply. Since the referral,
I have had an opportunity to discuss the various points in your letter with the City staff and
the City's consulting engineers, TD& H. Hopefully, this letter will provide an outline for a
resolution of your problem.
During the construction of infrastructure in the Teton Terrace subdivision, the contractor
Sandon Construction, stored equipment and materials upon your property. Neither the City,
nor TD& H, were aware that the use of your property was without permission or license.
Under the contract, if Sandon used or damaged property he will be required to provide the
City with a release prior to receiving final payment for Teton Terrace. A copy of this letter
will be forwarded to Sandon Construction, and I trust he will contact you regarding a release.
There are conflicting surveys in the area of Porta Villa and Teton Terrace which may have
contributed to the City's unintentional encroachment on your property. Further, it appears
that a hiatus exists between your property and Teton Terrace upon which the City caused to
be constructed a drainage ditch. From my prospective it would be of mutual benefit to
resolve platting errors, the hiatus and the City's encroachments amiably.
After discussing the matter with TD&H and the City staff, it is my inclination to offer what
I believe may be a solution to the entire problem. First of all, the City would restore all areas
disturbed by the Teton Terrace project to the same condition that existed prior to
construction. This would involve grading, seeding and herbicide application on Teton
Terrace and adjacent property. Secondly, the City would quit claim to you any interest it
might have in the hiatus and cooperate with you in titling said property in your name. In
consideration of the City's concessions, you would execute an easement for the drainage
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ditch from Teton Terrace to Yellowstone Street and from Yellowstone Street to Two Mile
Drive. If you accept the City's proposal, I believe all parties will be benefitted.
Please review the above suggested resolution and determine if it meets with your
expectations. I look forward to hearing from you regarding any suggestions you may have.
Sincerely,
Glen Neier
City Attorney
PC: City Manager
TD& H
Housing Manager, PECDD
Sandon Construction
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Fi. an effort to quickly resolve the conflicts, plegse =ist us by providing invoices for title
company easement searches, engineering services, surveying services and attorney fees. Be
advistd, the City has and is incurring similar expenses.
Sandon Construction is the contractor to the City responsible for the completion of Teton
Tenw,e. HaTp Line Constniction and Montana Power ComVany placed utffifies for the service
of future residenca. Montana Power is a utility; Harp was retained by them. Trespass and
damages caused by these parties are not the responsibility of the City.
The City and it's Engineers are convinced the "mystery" triangle exists. ... understand your
surveyor and engineer hold the same belief. The City will "quit clairn" any interest the City
MU have in the triangle to the Begg's. The City does not benefit by ownership. Only the Begg
property is benefitted by the additional of the ft-iangle to the parent parcel.
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City of the drainage ditch, Begg's could fence the property line as long as the fence did not
defeat the purpose of the drainage ditch. There is adequate right-of-way for the pavement in the
alley in Forta Villa to be located within ffie alley right-of-way. Lot I of Porta Villa number 3
bas a 10 fbot ac=n easement, which for the faw-plcx will have to suffice. This easement is
private.
Your property has been acknowledged as properties for future development. Development will
require drainage. The existing ditch does or can drain lands owned by Begg which at a
minimurn adjoin the ditch and rnay extend for several hundred feet westerly. The exact or
precise extent of the benefit would depend on the pattern of development. Secondly, since the
City would maintain the ditch, it's continued use would not economically impact the curTent or
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Responsibility for ir&q caused by the ditch would be subject to the courts decision. Becaus�
tho ditch would be fbr City bcncflt =d wonid, be maintained by thu City, Utt: City rnay be
responsible party.
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Kallspell
Telephone (406) 758-7700
FAX (406) 758-7758
Post Office Box 1997
Kalispell, Montana
Zip 59903-1997
January 15, 1997
Jerry Begg
220 Woodland Avenue
Kalispell, MT 59901
Re: Teton Terrace
Since your letter of November 26, 1996, the City and its Consulting Engineers, Thomas, Dean
and Hoskins, have been researching and analyzing the encroachments on your property adjacent
to Teton Terrace. The City is in a position to work cooperatively with you in resolving the
encroachments. In an effort to resolve the problem, please assist us by providing invoices for
title company easement searches, engineering services, surveying services and attorney fees.
Please be advised that the City is also incurring similar expenses in working out the difficulties.
Sandon Construction is the contractor to the City responsible for the completion of Teton
Terrace. Harp Line Construction and Montana Power Company placed utilities for the service
of future residences. Montana Power is a utility; Harp was retained by them. Trespass and
damages caused by these parties are not the responsibility of the City.
The City and its Engineers are convinced that "mystery triangle" exists. We understand your
surveyor and engineer hold the same belief. The City will "quit claim" any interest the City may
have in the triangle to you. However, the City does not own the triangle, nor is it benefitted by
ownership. Only your property is benefitted by the addition of the triangle to the parent parcel.
After the City "quit claims" its interest to you, and you grant an easement back to the City for
the drainage ditch, you would be free to fence the property line, so long as the fence did not
defeat the purpose of the drainage ditch. There is adequate right-of-way for the pavement in the
alley in Porta Villa to be located within the alley right-of-way. Lot 1 of Porta Villa #3 has a 10-
foot access easement, which for the four-plex, will have to suffice. This easement is private.
Douglas Rauthe
Mayor
Clarence W. Krepps
City Manager
City Council
Members:
Gary W. Nystul
Ward I
Cliff Collins
Ward I
Norbert F. Donahue
Ward II
Dale Haarr
Ward II
Jim Atkinson
Ward III
Lauren Granmo
Ward III
Pamela B. Kennedy
Ward IV
M. Duane Larson
Ward IV
Your property has been acknowledged as properties for future development. Development will
require drainage. The existing ditch does or can drain lands owned by you, which at a minimum
adjoin the ditch and may extend for several hundred feet westerly. The exact or precise extent of the
benefit would depend on the pattern of development. Secondly, since the City would maintain the
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ditch, it's continued use would not economically impact the current future owners of your property.
Responsibility for injury caused by the ditch would depend on the facts of a particular case.
However, because the ditch would be for City benefit and maintained by the City, the City would
be responsible for negligence on its part.
Enclosed are plans and a report which estimates the volume of run-off Teton Terrace contributes to
the ditch.
Please respond with you thoughts on our proposal.
Sincerely,
Glen Neier
City Attorney
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April 14, 1997
Mr Glen Neier
City Attorney
P O Box 1997
Kalispell MT 59903-1997
RE: Teton Terrace
Dear Glen,
Six months ago I contacted the City concerning problems with their
subdivision development Teton Terrace. These included unlawful
trespass, destruction of property, diversion of runoff water onto
our property and digging a drainage ditch on our property to facilitate
the runoff from Teton Terrace down the ditch.
Earlier this spring I viewed and photographed a small lake that formed
at the southeast corner of the property as aresult of the city's actions
which in addition filled the Two Mile Ditch to a level that almost spilled
over the road.
It had been my intent to try to resolve -this matter over the winter yet
to date the city has not made any proposal by way of resolving this problem.
I have incurred legal, survey and engineers expenses as well as spending
over 30 hours of my time on this so far.
My attorney has advised me to seek a court injunction to prohibit the city
from any further development of Teton Terrace until we have reached an
agreement.
If the city continues to ignore this situation that is exactly what I will
be forced to do.
A'