STONE, DAVID - 2015 - Laserfiche WebLink

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APR - 20-2015 00:53 FROM:LECAL DOCUMENT ASSI6 7146907722 TO:19497273660 P.3/7 Agreement and compliance with this Agreement shaft not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever, E OND: (a) Plaintiff will sign a Request for Dismissal of the Lndre Action with Prejudice form dismissing the above entitled case, (b) Defendants will notify Plaintiff s attorney when the settlement checks are ready. Thereafter, Plaintiff's attorney will send Defendants a fully signed original of this Agreement, and an executed original Request for Dismissal form, In turn, each Defendant will send via overnight mail to Plaintiffs counsel, a check in the amount of fifteen thousand dollars ($15,000,00) in full and complete settlement of all claims made against each respective •Defendant in the Lawsuit. Pach check will be made payable to "David Stono and his attorney of record, the Law Offices of David Craudall." The amounts described herein arc in full and comploto settlement for Plaintiffs claims for all damages alleged in the above - entitled action, (e) Defendant City sign a Request for Dismissal with Prejudice form dismissing its Grass - Complaint in the above entitled case. City expressly waives any and all claims that it may have against Green Giant for express or implied indemnification arising from Groen Giant's work that is the subject of the Lawsuit, (d) Plaintiff and Defendants agree that the foregoing mutual dismissals constitute full and complete settlement of all claims made against all Parries in this litigation and encompasses any and all rights and/or claims for damages, costs, or attorney's fees in connaotion with the Lawsuit, (e) Plaintiff acknowledges and agrees that Defendants have made no representations to him regarding the tax consequences of any amounts received by him pursuant to this Agreement, Plaintiff agrees that he and be alone is liable for all taxes, if any, that are owed by him on any amount received hereunder including interest and penalties. Plaintiff will hold Defendants hamtless from any and all claims made by federal, state, or local taxing authorities or lien holders, including the holders of any .liens for medical expenses such as Kaiser Permanent®, against Plaintiff on amounts owed by him, (f) Plaintiff agrees that he shall not take any action to publicize the resolution of the Lawsuit or the terms of this Agreement, including but not limited to, speaking with the media or producing press releases. T RD: Plaintiff represents that, with the exception of the above- entitled action, he has not filed any complaints, claims, or actions against Defendants including Mutuul Rclnu:io and Settlement AVaenaeaf �• Document No, 25415