MARY DEE DORMAN 3/23/2020 - Laserfiche WebLink

w 4 • RELEASE AND SETTLEMENT AGREEMENT Release In consideration of payment to the undersigned, MARY DEE DORMAN, a single woman, in the sum of Ten Thousand Dollars ($10,000.00), receipt of which is hereby acknowledged, the undersigned does hereby release and forever discharge the CITY OF EVERETT, a municipal corporation, its agents, employees, assigns and insurers from all claims, demands, damages, actions or causes of action arising out of an incident that occurred on or about October 8, 2018, and detailed in Plaintiff's claim for damages filed with the City. This Release includes but is not limited to the specific release and waiver of any private right of action the undersigned may have against the above-named released parties under 42 USC §1395y(b)(3)(A). Claims Against the Proceeds, Indemnity,and Hold Harmless The undersigned agrees to satisfy all liens, subrogation claims, or other rights or interests arising from the accident pertaining directly to the undersigned and asserted in or against the above- stated settlement proceeds that pertain directly to the undersigned. The undersigned also agrees to indemnify The City of Everett's its agents, employees and insurers and hold those parties harmless from any and all such liens, subrogation interests or other rights arising from this incident. This includes but is not limited to any and all liens of workers compensation insurance, hospital liens, ambulance liens, attorney liens, unpaid medical bills, insurer's claims for reimbursement of Personal Injury Protection benefits and the liens of any public agencies providing medical or other assistance including but not limited to Medicaid,Medicare. Medicare's Interests The undersigned is a Medicare beneficiary. The undersigned and her counsel agree to satisfy Medicare's interest out of the settlement funds before any funds are distributed to Ms.Dorman. Nature of Damage and Basis of Settlement In making this release, it is understood and agreed that reliance is placed wholly on the judgment, belief and knowledge of the undersigned as to the value of Plaintiff's personal injury claim. Settlement Not an Admission of Liability It is understood that the settlement which is evidenced by this document is in the spirit of compromise and is not intended as an admission of liability on behalf of any party. The pending lawsuit in the Snohomish County Superior Court, under Cause No. 1 9-2-03 1 89-3 1, will be dismissed with prejudice once the settlement funds are paid. RELEASE& SETTLEMENT AGREEMENT- 1 ORIGINAL .1AF/6085-92/1058750