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Insurance Trust agrees to pay Wayne C. Wells, Jr., and his attorneys, Ahlberg Law, PLLC,
<br />the total sum of $6,500 (Six -thousand -five -hundred dollars and no cents). The Releasees
<br />make no representation or warranties about any particular tax treatment of the payment.
<br />Wayne C. Wells, Jr. enters into this Agreement only after consulting with his own attorney
<br />and/or tax advisor as to the characterization and treatment of such payment. Wayne C. Wells,
<br />Jr. agrees that he alone, and none of the Releasees or the League of Minnesota Cities
<br />Insurance Trust, shall be liable for any taxes that he may owe on account of said payment.
<br />3. Waiver and Release of All Claims. In exchange for the consideration provided by this
<br />Agreement, Wayne C. Wells, Jr. hereby waives all claims against, releases, and forever
<br />discharges
<br />— The Releasees; and
<br />— The former, current, and future elected officials, officers, agents, and employees of the
<br />Releasees, together with their successors and assigns, in their individual and official
<br />capacities; and
<br />— The League of Minnesota Cities Insurance Trust, and all and each of its former,
<br />current, and future officers, directors, principals, employees, representatives, and
<br />agents
<br />of and from any and all actions, causes of actions, liabilities, suits, debts, sums of money,
<br />accounts, controversies, omissions, damages, judgments, claims and demands whatsoever,
<br />state or federal, in law or in equity, whether known or unknown, asserted or unasserted,
<br />suspected or unsuspected, that have, could be, or could have been raised by Wayne C. Wells,
<br />Jr., arising from or relating in any way to the events of November 12, 2011.
<br />4. Stipulation of Dismissal with Prediudice. Wayne C. Wells, Jr. agrees that his counsel
<br />shall, on his behalf, execute a stipulation of dismissal with prejudice to secure the dismissal
<br />of his pending civil action against the City of Ramsey and Jerad Dixon, and that pursuant to
<br />Fed. R. Civ. P. 41(a)(1)(A)(ii), this settlement shall become effective after filing the
<br />stipulation of dismissal signed by counsel for all parties who have appeared.
<br />5. Voluntary and Knowing Action. Each person signing this Agreement specifically
<br />acknowledges that he/she has read the terms of the Agreement in full, has been free to
<br />consult with an attorney of his or her own choosing, understands the terms of this
<br />Agreement, and agrees to be bound by this Agreement in full. Those signing below in a
<br />representative capacity fully affirm or verify that they are authorized to execute this
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