1. Settlement. The Parties agree, as between each other, that the dismissal of the
<br /> Parties' Claims between one another with prejudice is in exchange for a waiver of costs, fees,
<br /> and any other expenses.
<br /> 2. Release. In consideration of the promises and covenants made and expressed herein, and
<br /> except as otherwise provided herein, Plaintiffs on the one hand, and Defendant on the other hand,
<br /> on behalf of themselves, their predecessors, owners, members, successors, assigns, attorneys,
<br /> insurance carriers, agents, consultants, servants, employees, directors,representatives, family
<br /> members, and heirs do hereby release,relieve, acquit, and forever discharge the other, including
<br /> each others' predecessors, owners,members, successors, assigns, attorneys, insurance carriers,
<br /> agents, consultants, servants, employees, directors, representatives, family members, and heirs
<br /> (i.e., Plaintiffs on the one hand release Defendant on the other hand, and Defendant on the one
<br /> hand releases each Plaintiff on the other hand and Plaintiffs and Defendant release such
<br /> others' predecessors, owners, members, successors, assigns, attorneys, insurance carriers, agents,
<br /> consultants, servants, employees, directors, representatives, family members, and heirs) from any
<br /> and all Claims. The releases under this Section 2 become effective immediately after the
<br /> Plaintiffs receive the entire T. Bailey, Inc., payment. The Parties agree that, to the extent
<br /> Plaintiffs are required to file a dismissal, that it can be done ten (10) days after Plaintiffs receive
<br /> funding from T. Bailey, Inc.
<br /> 3. Entire and Final Agreement. The Parties understand, acknowledge and
<br /> agree that this Settlement Agreement constitutes the entire and fmal compromise settlement
<br /> between them, and there have been no agreements, representations or warranties made by any of
<br /> the Parties or by their attorneys, except as specifically set forth herein.
<br /> 4. Counterparts. This Settlement Agreement may be executed electronically,
<br /> in one or more counterparts, all of which together shall constitute in the aggregate one and the
<br /> same instrument. Each executed counterpart shall be deemed an original and shall have the same
<br /> force and effect as an original.
<br /> 5. Authority. Each of the Parties represents to each other that it has legal power
<br /> and authority to enter into this Settlement Agreement and that all actions necessary to authorize
<br /> this Settlement Agreement have been taken and are in full force and effect and have not been
<br /> modified, amended, or revoked. All parties to this Settlement Agreement expressly warrant and
<br /> represent that they have not previously assigned, pledged, or in any other manner sold or
<br /> transferred any of the Claims that are released herein.
<br /> 6. Choice of Law, Jurisdiction and Venue. This Settlement Agreement shall be
<br /> enforced and construed in accordance with the laws of the state of Washington. Should any suit
<br /> arise out of this Settlement Agreement, all parties hereto consent to the personal jurisdiction of
<br /> the state of Washington. The Parties further agree that the Superior Court of Snohomish County
<br /> shall be the exclusive legal forum for the resolution of any dispute which may arise out of or be
<br /> Case#21-2-00611-31 Page 2 of 4 Settlement Agreement
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