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SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of All Claims ("Agreement") is made by and <br />between Wayne C. Wells, Jr. ("Wells" or "Plaintiff') and the following, who shall be <br />referred to collectively as the Releasees: <br />— The City of Ramsey <br />— Jerad Dixon <br />WHEREAS, Officer Jerad Dixon brought Wayne C. Wells, Jr., into custody on or about <br />November 12, 2011; and; <br />WHEREAS, on or about March 29, 2013, Wells commenced a civil action against the <br />Releasees in the Minnesota State District Court in the Tenth Judicial District; and <br />WHEREAS, on or about May 24, 2013, the Releasees removed the action to the United <br />States District Court for the District of Minnesota, File No.: 13-CV-1241 (ADM/FLN). <br />WHEREAS, Wells claimed, inter alia, the Releasees were legally liable to him for <br />violations of 42 U.S.C. § 1983, and for assault and battery, and alleging he sustained <br />physical injury as a result of the incident on November 12, 2011; and <br />WHEREAS, the undersigned parties have successfully conciliated all issues in dispute <br />and have agreed to a full settlement of any and all claims that Wells brought or could have <br />brought. <br />NOW THEREFORE, in consideration of the recitals set forth above and the promises <br />made in this Agreement, the parties agree and intend to be legally bound by the following <br />terms: <br />1. No Admission of Wrongful Conduct or Liability. It is expressly understood and <br />agreed that this Settlement Agreement and Release of Claims does not constitute, nor shall it <br />be construed as, an adjudication or finding on the merits of any claim or potential claim by <br />Wayne C. Wells, Jr., nor does this Settlement Agreement and Release of Claims constitute, <br />nor shall it be in any manner construed as, an admission of any wrongful conduct or liability <br />on the part of the Releasees or their respective elected officials, employees, agents or <br />representatives. <br />2. Consideration to Wayne C. Wells, Jr. In settlement of and consideration for the <br />release of any and all claims, asserted or unasserted, known or unknown, arising out of or <br />relating in any way to the events of November 12, 2011, the League of Minnesota Cities <br />Page 1 of 4 <br />