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10, 2010, Ecology issued a letter to the City of Everett acknowledging its VCP Claim <br /> submissions and containing Ecology's opinions regarding the completion of proposed cleanup <br /> under authority of the Model Toxics Control Act (collectively referenced below as the "VCP <br /> Claim"); <br /> WHEREAS, Safety Mutual Casualty Corporation, now known as Safety National <br /> Casualty Corporation, issued or is alleged to have issued certain insurance policies to the City of <br /> Everett; <br /> WHEREAS, on or about August 10, 2018, the City of Everett tendered the VCP Claim <br /> and the alleged site contamination at the GTS Site to Safety National (as hereinafter defined) for <br /> defense and indemnity, including pre-tender costs, under one or more of the Policies (as <br /> hereinafter defined); <br /> WHEREAS, a dispute exists between the City of Everett and Safety National concerning <br /> whether Safety National is obligated, in whole or in part, to defend or indemnify the City of <br /> Everett in connection with the VCP Claim, to pay any costs relating to, arising out of and/or in <br /> connection with Environmental Contamination at, around, or emanating from the GTS Site or <br /> otherwise, and whether Safety National has any obligation to the City of Everett under the <br /> certain alleged insurance policies; <br /> WHEREAS,the Parties (as hereinafter defined) believe it is in their best interests to fully <br /> and finally resolve all disputes and any and all past, present and future disputes, without further <br /> litigation, relating to, arising out of and/or in connection with the GTS Site, the VCP Claim, and <br /> any and all alleged obligations of the Policies with respect to Claims concerning the GTS Site <br /> and the VCP Claim; <br /> WHEREAS, the Parties acknowledge their belief that confidentiality is not feasible for a <br /> Settlement Agreement and Site Release <br /> Page-2 <br /> 2625918/1470.0003 <br />