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E. The City expressly denies the allegations of the State as set forth herein.This Agreement <br /> is neither an admission of facts or liability by the City,nor a concession by the State that <br /> its allegations are not well founded. <br /> F. To avoid the delay,expense, inconvenience, and uncertainty of protracted litigation,the <br /> Parties mutually desire to reach a full and final settlement as set forth below. <br /> HI. TERMS AND CONDITIONS <br /> NOW, THEREFORE, in reliance on the representations contained herein and in <br /> consideration of the mutual promises, covenants and obligations set forth in this Agreement, and <br /> for good and valuable consideration as stated herein,the Parties agree as follows: <br /> 1. The City of Everett agrees to pay to the State of Washington the sum of seventy-three <br /> thousand, one hundred and fifty eight dollars ($73,158); plus, if applicable, accrued <br /> interest as set forth in Paragraph 4 (Settlement Amount). The Settlement Amount shall <br /> constitute a debt immediately due and owing to the State of Washington on the Effective <br /> Date of this Settlement Agreement and subject to the terms of this Agreement. The debt <br /> shall forever be discharged by payments to the State of Washington,under the following <br /> terms and conditions. <br /> (a) The City of Everett shall pay by check the sum of seventy-three thousand,one hundred <br /> and fifty eight dollars ($73,158); plus, if applicable, accrued interest according to the <br /> terms described in Paragraph 4,no later than fourteen(14)business days after the date <br /> • this Settlement Agreement is finalized as provided in Paragraph 18 below. <br /> (b) The City shall make the check payable to: <br /> DSHS Office of Financial Recovery and deliver such check to the <br /> Medicaid Fraud Control Unit, 2425 Bristol Court SW, Olympia, <br /> WA 98502. <br /> (c) The City shall take appropriate measures within its recordkeeping systems to ensure its <br /> ALS and BLS claims are properly coded and submitted for reimbursement. <br /> 2. Subject to the exceptions in Paragraph 3 below,in consideration of the obligations of the <br /> City of Everett, as set forth in this Agreement,and conditioned upon receipt by the State <br /> of the Settlement Amount, the State agrees to release the City, its predecessors and <br /> current and former successors, transferees, heirs, and assigns (collectively, the "City of <br /> Everett Released Entities"), from any civil or administrative monetary cause of action <br /> that the AGO/MFCU and HCA could otherwise assert for any claims submitted or caused <br /> to be submitted as a result of the Covered Conduct identified in Paragraph E. <br /> 3. Notwithstanding the releases given in Paragraph 2 of this Agreement, or any other term <br /> of this Agreement,the following claims of the State are specifically reserved and are not <br /> released: <br /> {AG51604567.DOCX;2/13113.000005/} Page 2 of 7 <br />