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CITY <br /> SETTLEMENT AGREEMENT <br /> THIS SETTLEMENT AGREEMENT is entered into this (g day of October, 2019, by <br /> and between the following parties: <br /> A. The City of Everett, a municipal corporation; and <br /> B. Jamie Wallin, Plaintiff. <br /> This Agreement is entered into for the purpose of settling certain claims between the City of <br /> Everett and Jamie Wallin, as such terms are defined herein, which claims were asserted or could <br /> have been asserted in lawsuits as defined below or claims based on any Public Records Act(PRA) <br /> request as defined below. <br /> 1. Definitions. <br /> a. City. "City" means the City of Everett, a municipal corporation, its <br /> successors, departments, assigns, agents, current and former councilmember, employees, <br /> officers and attorneys. <br /> b. Plaintiff "Plaintiff'means Jamie Wallin. <br /> c. Lawsuits. "Lawsuits" means all Claims brought in Snohomish County <br /> Superior Court Cause No. 16-2-02860-6; No. 16-2-02813-4; 17-2-11805-31; and 19-2- <br /> 04566-31. <br /> d. Claims. "Claims" shall encompass all claims, causes of action related to <br /> the PRA requests at issue in the Lawsuits made by or on behalf of the Plaintiff, including <br /> all claims based on those PRA request. <br /> e. PRA Requests. "PRA Requests" refer to the PRA requests by Plaintiff at <br /> issue in the four identified lawsuits. <br /> 2. Releases; Dismissal of PRA Lawsuits. <br /> a. Release of Claims. Subject to the reservations in paragraph 2.b, Plaintiff <br /> expressly releases and shall be deemed to have forever discharged the City from any and <br /> all Claims, as defined above, including any Claims based on the Lawsuits and any PRA <br /> requests. It is hereby agreed that this Agreement is a compromise and a full settlement, <br /> accord and satisfaction of all Claims and PRA Requests. <br /> b. Proceedings in the PRA Lawsuits: The Parties agree that as part of this <br /> Settlement Agreement that they will coordinate to set a hearing and allow for in camera <br /> review to address the challenges Plaintiff has made to certain redactions. The Parties <br /> further reserve the right to appeal any ruling on exemptions made after the in camera <br /> review. The Parties further agree that all other issues related to the Claims have been <br /> WALLIN PRA LAWSUITS/COE SETTLEMENT AGREEMENT-1 of 3 <br />