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SETTLEMENT AGREEMENT <br />This Settlement Agreement (the "Agreement") is entered into by: SAVANAH PRIMEAU <br />and DRAKE ROSENLUND (together, the "Plaintiffs"); and the CITY OF EVERETT (the "City") <br />(collectively, the "parties" and each, a "party"). <br />Recitals <br />A. Plaintiffs commenced a lawsuit against the Everett Police Department (a <br />department of the City), Jared Corson, and other unnamed individuals (collectively, <br />' Defendants") in the Washington State Superior Court for Snohomish County, cause number 21- <br />2-06122-31 (the "Lawsuit"). <br />B. To avoid the expense and uncertainty associated with continuing to litigate the <br />Lawsuit, the parties have agreed to the settlement set forth in this Agreement. <br />Agreement <br />NOW, THEREFORE, in consideration of the performance described herein and for other <br />good and valuable consideration, the sufficiency of which is hereby acknowledged, the parties <br />agree as follows: <br />1. Denim of Liability. The parties acknowledge that this Agreement is not to be <br />construed as an admission of liability by any party and that the City and the Everett Police <br />Department expressly denies any hability or wtongdomg. <br />2. Effective Date. This Agreement is effective as of the date the last party signs the <br />agreement. <br />3. Settlement Payment. The City will pay the sum of $725,000.00 (the ``Settlement <br />Payment") to Plaintiffs within 30 days of the Effective Date. The City will pay the Settlement <br />Payment to Plaintiffs by delivery of a check in the amount of the Settlement Payment payable to <br />"Albert Law PLLC in trust for Savanah Primeau and Drake Rosenlund," and delivered to <br />Plaintiffs' counsel at 3131 Western Avenue, Suite 410, Seattle, WA 98121 <br />4. Stipulated Dismissal. Upon signature of this Agreement by all parties, the parties <br />through their counsel shall jointly notify the Court that a settlement has been reached, and <br />request that no orders been entered in the case pending formal dismissal. Within 7 days of <br />delivery of the Settlement Payment to Plaintiffs' counsel, the parties through their respective <br />counsel of record shall stipulate to entiy of an order dismissing with prejudice the Everett Police <br />Department and all Defendants except Jared Corson from the Lawsuit and without any award of <br />attorneys' fees or costs The parties acknowledge that the Court's ruling regarding Plaintiffs' <br />Motion foi Partial Summary Judgment against Defendant Everett Police Depaitment on the Issue <br />of Strict Liability (the "Motion") shall have no force and effect and may not be used as <br />precedent, and if the Court enters an order regarding the Motion (the "Summary Judgment <br />Settlement Agreement Page 1 of 3 <br />