Sheldon R. and Phyllis Milenbach, et al. - Page 9

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          to the 1984 Summer Olympics were abandoned.  In 1985 and 1986,              
          the Raiders worked with architects and contractors on the design            
          and planning of the suites.  The construction of the suites began           
          in early 1987 but was halted on or about February 18, 1987.                 
          Construction was stopped due to a dispute between the Raiders and           
          the LAMCC over the obligations of the LAMCC to perform certain              
          improvements to the LA Coliseum.                                            
               The Raiders made no payments on the LAMCC loan.  The Raiders           
          did not construct the suites at the LA Coliseum.                            
               The LAMCC did not seek repayment of the $6.7 million until             
          after the Raiders signed a memorandum of agreement with the City            
          of Irwindale (Irwindale MOA), discussed infra.  The LAMCC filed a           
          lawsuit against the Raiders on September 30, 1987, claiming that            
          the Raiders were in breach of their lease and demanding repayment           
          of the $6.7 million.  In the Raiders’ answer to the LAMCC                   
          complaint, the Raiders alleged:                                             
                    That Raiders has not constructed the suites or the                
               press box improvements referred to in the lease                        
               agreement because, by reason of considerations                         
               reasonably deemed important and significant to Raiders,                
               including plaintiff’s [LAMCC’s] breach of its                          
               commitment to modernize and reconfigure the stadium as                 
               hereinafter alleged, Raiders was never under any                       
               obligation to construct the suites or press box                        
               improvements, and, Raiders has not obtained a building                 
               permit or the surety bonds referred to in the lease                    
               agreement * * *  [Emphasis added.]                                     
          The lawsuit was settled on September 11, 1990, with the parties             
          entering into a mutual release.                                             






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