Common use of Release and Discharge Clause in Contracts

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff hereby completely releases and forever discharges Defendant and Insurer from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) including, without limitation, any and all known or unknown claims to Plaintiff, or any of Plaintiff's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the Defendant. 1.2 This release and discharge shall also apply to Defendant's and Insurer's past, present and future officers, directors, stockholders, attorney's, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete settlement among the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's decision to enter into this Settlement Agreement. The Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by the parties that this settlement is a compromise of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly denied.

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff Parties hereby completely releases release and forever discharges Defendant discharge each other individually and Insurer each other’s officers, directors, shareholders, agents, representatives, parent, subsidiary and any affiliated entities, attorneys and accountants, and their successors and assigns from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claimsrights of action, rightsobligations, damages, costs, losses of services, expenses and compensation or liabilities of any nature whatsoever, including but not limited to damages, principal, penalties, and/or interest, whether based on a tortat law or in equity or by statute, contract known or other theory of recoveryunknown, which the Plaintiff now hasthrough and to include May 31, or which may hereafter accrue or otherwise be acquired2016, on account of, or may in any way grow arising out of, in connection with or which are related to the subject of Action, whether or not raised in the Complaint Action (and all related pleadings) includingcollectively, without limitation, any and all known or unknown claims to Plaintiff, or any of Plaintiff's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the Defendant“Claims”). 1.2 This release Release of Claims shall be fully binding and discharge shall also apply to Defendant's a complete settlement among the Parties, and Insurer's their respective past, present and future officers, directors, members, stockholders, attorney'sattorneys, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, heirs, and assigns assigns, and all other persons, firms or corporations with whom any of the former have been, are now, now or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding The Parties acknowledge and complete settlement among the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees agree that the release Release and discharge Discharge set forth above is a general releaserelease and is without limitation. Plaintiff Petitioner expressly waives and assumes the risk of any and all claims for damages Claims which exist as of this date, but of which the Plaintiff does Petitioner do not know or suspect to exist, whether through ignorance, oversight, error, negligence, negligence or otherwise, and which, if known, would materially affect Plaintiff's Petitioner’s decision to enter into this Settlement Agreement. The Plaintiff Petitioner further agrees that Plaintiff has they have accepted payment of the sums consideration and payments specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff Each Party assumes the risk that the facts or law may be other than Plaintiff either Party believes. It is understood and agreed to by the parties Parties that this settlement is a compromise of a doubtful disputed Claims and disputed claim, and the payments are is not to be construed be 1.4 The Parties agree that Respondent is solely responsible for any and all surface damages, environmental damages (including surface and sub-surface damages) and any other causes of action associated with the Nielsen 1-20B1. If there ever arises any action against Respondent as an admission of liability on it is associated with the part of the DefendantNielsen 1-20B1, by whom liability is expressly deniedRespondent shall indemnify and hold harmless Petitioner.

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff hereby completely complete­ly releases and forever discharges Defendant Insured and Insurer from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) incident described in Recital A above, including, without limitation, any and all known or unknown claims for bodily and personal injuries to Plaintiff, or any future wrongful death claim of Plaintiff's representatives representa­tives or heirs, which have resulted or may result from the alleged acts or omissions of the DefendantInsured. 1.2 This release and discharge shall also apply to DefendantInsured's and Insurer's past, present and future officers, directors, stockholders, attorney'sattorneys, agents, servantsser­vants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete settlement among the Plaintiff, the Defendant Insured and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does not know or suspect to exist, whether through ignorance, oversight, error, negligencenegli­gence, or otherwise, and which, if known, would materially affect Plaintiff's decision to enter into this Settlement Agreement. The Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by the parties that this settlement is a compromise of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the DefendantInsured, by whom liability is expressly denied.

Release and Discharge. 1.1 In That in consideration of the payments set forth in Section 2, Plaintiff hereby completely releases and forever discharges Defendant and Insurer from any and all past, present or future claims, demands, obligations, actions, causes full discharge of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) including, without limitation, any and all known or unknown claims to Plaintiff, or any of Plaintiff's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the Defendant. 1.2 This release and discharge shall also apply to Defendant's and Insurer's past, present and future officersclaims arising out of an automobile accident on June 20, directors2006, stockholdersand the allegations set forth in Plaintiff’s Complaint, attorney'sMaricopa County Superior Court Cause No.CV2007-010922, agentsand in full and complete discharge of all personal injury claims that could be asserted by Plaintiff, servantsher heirs, executors, administrators, personal representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any as a result of the former have beenalleged actions or omissions of Defendants, are now, or may hereafter be affiliated. 1.3 This release, on Defendants agree to pay to Plaintiff the part sum of the Plaintiff, shall be a fully binding and complete settlement among the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's decision to enter into this Settlement Agreement. The Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the risk that the facts or law may be other than Plaintiff believesOne Hundred Ten Thousand Dollars ($110,000.00). It is expressly understood and agreed to by the parties that this settlement Settlement Agreement and Release is executed as a compromise of a doubtful disputed claim and disputed claim, and the payments are that said payment contemplated herein is not in any manner to be construed as an admission of liability on the part of the DefendantDefendants, by whom their agents, servants, employees and attorneys, and any and all other persons, firms or corporations, such liability is being expressly denied. This Settlement Agreement and Release shall apply to all claims, whether known or unknown, on the part of all Parties to this Agreement. In consideration of the payment called for herein, Plaintiff completely releases and forever discharges Defendants, their agents, servants, successors, heirs, executors and administrators, and all other persons, firms, corporations, associations or partnerships of and from any and all claims, actions, causes of action, demands, rights, damages, costs, loss of service, expenses and compensation whatsoever, including medical care provider liens, workers compensation liens, court costs, legal expenses and attorneys’ fees which the undersigned now has or had or which may hereafter accrue on account of or in any way growing out of any and all known and unknown, foreseen and unforeseen bodily and personal injuries resulting from the accident, casualty or event listed in Plaintiff’s Complaint. Plaintiff acknowledges that the payment called for herein is all that she will receive from Defendants and that no promise for any other or further consideration has been made by anyone. This Settlement Agreement and Release shall be a full, binding and complete settlement between the Parties, save only and excepting the executory provisions of this Agreement.

Release and Discharge. 1.1 4.1 In consideration of the payments payment set forth in Section 23.0, Plaintiff City/Town, for itself, its elected and appointed officers, employees, agents, administrators, successors and assigns, does hereby completely releases release, acquit and forever discharges Defendant discharge the County, its elected and Insurer appointed officials, officers, employees, agents, administrators, successors and assigns, from and against any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claimssubrogation rights, reimbursement rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract contract, or any other theory of recovery, which the Plaintiff said parties now hashave, or which may hereafter accrue or otherwise be acquired, acquired or asserted on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) Administrative Fee Dispute, including, without limitation, any and all known or unknown claims to Plaintifffor damages, tax or fee refunds, interest, breach of contract, or any of Plaintiff's representatives and all known or heirs, unknown claims for subrogation and/or reimbursement which have resulted or may result from the alleged acts or omissions of the Defendant. 1.2 This release and discharge shall also apply to Defendant's and Insurer's pastCounty, present and future its elected or appointed officials, officers, directors, stockholders, attorney'semployees, agents, servantsadministrators, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and or assigns and all other persons, firms or corporations with whom any of related to the former have been, are now, or may hereafter be affiliated. 1.3 Administrative Fee Dispute. This release, on the part of the Plaintiff, release shall be a fully binding and complete settlement among between the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successorsparties. 1.4 4.2 It is understood and agreed to by the Parties hereto that this settlement is not to be construed as an admission of liability on the part of County, by whom liability is expressly denied and that this Agreement is entered into solely to resolve the Administrative Fee Dispute and avoid the time and expense of litigation. 4.3 The Plaintiff City acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff release and expressly waives and assumes the risk of any and all claims for damages related to the Administrative Fee Dispute which exist as of this date, but of which the Plaintiff does not know whether known or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's decision to enter into this Settlement Agreementunknown. The Plaintiff parties further agrees that Plaintiff has accepted agree they have agreed to exchange payment of the sums sum specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes fact and mutually assume the risk that the facts or law may be other than Plaintiff believesthey believe and which facts, if known, would materially affect their decision to enter into this Settlement Agreement. It is understood The parties hereby acknowledge and agreed expressly waive any and all rights based upon the provisions of California Civil Code Section 1542, which reads as follows: “A general release does not extend to by claims which the parties that this creditor does not know or suspect to exist in his or her favor at the time of executing the release, which, if known to him or her, must have materially affected his or her settlement is a compromise of a doubtful and disputed claim, and with the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly denieddebtor.”

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff hereby completely releases and forever discharges Defendant and Insurer from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) including, without limitation, any and all known or unknown claims for bodily and personal injuries to Plaintiff, or any future wrongful death claim of Plaintiff's ’s representatives or heirs, which have resulted or may result from the alleged acts or omissions of the Defendant. 1.2 This release and discharge shall also apply to Defendant's ’s and Insurer's ’s past, present and future officers, directors, stockholders, attorney'sattorneys, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete settlement among the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's ’s decision to enter into this Settlement Agreement. The Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by the parties that this settlement is a compromise of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly denied.

Release and Discharge. 1.1 In consideration of the payments monetary amount set forth below in Section Paragraph 2, Plaintiff hereby and the non-monetary provisions set forth below in Paragraph 3, Claimants completely releases release and forever discharges Defendant and Insurer discharge the State from any and all past, present present, or future claims, demands, obligations, actions, causes of action, wrongful death claimsand legal theories, rightswhether known or unknown, that have resulted or may result from the Incident. This includes but is not limited to any claims or causes of action for economic damages, noneconomic damages, injuries, attorneys’ fees, costs, losses or other relief arising out of servicesthe Incident, expenses and compensation whether or not alleged in the Claim. Claimants release the State from any future claims of any nature whatsoeverkind, whether based on a tort, contract known or other theory of recoveryunknown, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) including, without limitation, any and all known or unknown claims to Plaintiff, or any of Plaintiff's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the Defendant. 1.2 State. This release and discharge shall also apply applies to Defendant's and Insurer's the State’s past, present present, and future officers, directors, stockholders, attorney'sattorneys, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, insurers, and assigns assigns, and all other persons, firms firms, or corporations with whom any of the former have been, are now, now or may hereafter be affiliated. 1.3 . This release, on the part of the Plaintiff, shall be release constitutes a fully binding and complete settlement among the Plaintiff, the Defendant between Claimants and the InsurerState, including the Claimants’ heirs, beneficiaries, assigns, and their heirs, assigns successors. Claimants acknowledge and successors. 1.4 The Plaintiff acknowledges and agrees agree that the release and discharge set forth above is a general release. Plaintiff Claimants expressly waives waive and assumes assume the risk of any and all claims for damages which that exist as of this date, date but of which the Plaintiff does Claimants do not know or suspect to exist, whether through ignorance, oversight, error, negligence, ignorance, or otherwise, otherwise and whichthat, if known, would materially affect Plaintiff's Claimants’ decision to enter into this Settlement Agreement. The Plaintiff It is understood and agreed that the sums set forth below, paid to Claimants, are in part to compensate them for unknown injuries and/or damages that may be discovered in the future. Claimants further agrees agree that Plaintiff has Claimants have accepted payment of the sums specified herein as a complete compromise of all matters involving disputed issues of law and fact. Plaintiff assumes Claimants assume the risk that the facts or law may be other than Plaintiff believeswhat Claimants believe. It is understood Claimants hereby instruct their attorneys to not pursue litigation in this matter as outlined above and agreed to by the parties that this settlement is a compromise of a doubtful below. Settlement Agreement and disputed claim, and the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly denied.Release Doc ID: 415b2fe8e7dd01a0c4e556987b253a5ea0f2096b

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff Claimant hereby completely releases and forever discharges Defendant LNB from all claims asserted to date by claimant with respect to alleged damages incurred by claimant in the course of her employment with LNB and Insurer from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, punitive damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff Claimant now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow arise out of, or which are the subject of the Complaint (and all related pleadings) Claimant’s employment with LNB including, without limitation, any and all known or unknown claims for bodily and personal injuries to PlaintiffClaimant, back pay or front pay, Workers’ Compensation claims, or any of Plaintiff's representatives claims which were asserted to date. Claimant specifically reserves the right to file for unemployment compensation, and LNB reserves the right to oppose or heirs, which have resulted or may result from the alleged acts or omissions of the Defendantcontest that filing and Claimant’s right to unemployment compensation. 1.2 This release and discharge Agreement shall also apply to Defendant's and Insurer's LNB’s past, present and future officers, directors, stockholdersshareholders, attorney'sattorneys, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and predecessors, successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliatedassigns. 1.3 This release, on the part of the Plaintiff, Agreement shall be a fully binding and complete settlement among the Plaintiffupon Claimant’s heirs, the Defendant and the Insurerexecutors, and their heirsadministrators, assigns and successors. 1.4 The Plaintiff Claimant acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff Claimant expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff Claimant does not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's Claimant’s decision to enter into this Settlement Agreement. The Plaintiff Claimant further agrees that Plaintiff Claimant has accepted payment of the sums sum specified herein below as a complete compromise of matters involving disputed issues of law and fact. Plaintiff Claimant assumes the risk that the facts or law may be other than Plaintiff as Claimant believes. It is understood and agreed to by the parties Claimant that this settlement is a compromise of a doubtful and disputed claim, and the payments are payment set forth in Section 2 is not to be construed as an admission of liability on the part of the DefendantLNB or any of its employees, by whom liability is expressly denied. 1.5 Claimant agrees to assume responsibility for all outstanding liens, known or unknown, including medical liens and subrogation interests, upon the proceeds of this settlement. In the event that any liens or subrogation interests are in force, Claimant agrees to hold harmless and indemnify LNB and its officers, employees, directors, partners and agents, for all said liens including costs, expenses, and attorney’s fees incurred because of said liens or assertion of subrogation interests. 1.6 Claimant specifically releases any claims or causes of action that she had, has, or may have into the future for any form of interest, including any interest set forth in Ohio Revised Code § 1343.03. 1.7 Claimant agrees to defend, indemnify and hold harmless LNB with respect to any claims that might be asserted now or in the future against LNB by any of Claimant’s children or by Claimant’s spouse for any derivative claim that they may have including, but not limited to, loss of services, consortium and companionship.

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff hereby completely releases and forever discharges Defendant Insured and Insurer from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) incident described in Recital A above, including, without limitation, any and all known or unknown claims for bodily and personal injuries to Plaintiff, or any future wrongful death claim of Plaintiff's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the DefendantInsured. 1.2 This release and discharge shall also apply to DefendantInsured's and Insurer's past, present and future officers, directors, stockholders, attorney'sattorneys, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete settlement among the Plaintiff, the Defendant Insured and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's decision to enter into this Settlement Agreement. The Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by the parties that this settlement is a compromise of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the DefendantInsured, by whom liability is expressly denied.

Release and Discharge. 1.1 In consideration of a. The P&J and its owners, agents, employees, and affiliates (“Releasing P&J Parties”) hereby release, discharge, and agree to hold the payments set forth in Section 2Borough and its current and former councilors, Plaintiff hereby completely releases mayors, officials, employees, agents, attorneys, representatives and forever discharges Defendant assigns (collectively, “Released Borough Parties”), free and Insurer harmless from and against any and all pastrights, present or future claims, debts, demands, acts, agreements, liabilities, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint fees (and all related pleadings) including, without limitation, any those of attorneys), expenses, actions and/or causes of action of every nature, character and all description, whether known or unknown claims to Plaintiffunknown, suspected or unsuspected which are, or any of Plaintiff's representatives or heirscould have been, which have resulted or may result from alleged in the alleged acts or omissions Lawsuit. The Releasing P&J Parties acknowledge and agree that the Release and Discharge set forth above is a GENERAL RELEASE and shall be fully binding and a complete settlement by them of the Defendant. 1.2 This release Released Borough Parties and discharge shall also apply to Defendant's and Insurer's past, present and future officers, directors, stockholders, attorney's, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns any and all other persons, firms firms, or corporations with whom any of the former have been, who are now, or may hereafter be affiliated. 1.3 This release, on liable for claims that are or could have been asserted in the part of the Plaintiff, shall be a fully binding Lawsuit. The Releasing P&J Parties expressly waive and complete settlement among the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff expressly waives and assumes assume the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does they do not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's their decision to enter into this Settlement AgreementRelease. The Plaintiff further agrees Releasing P&J Parties acknowledge and agree that Plaintiff no statement of fact or opinion has accepted payment been made by the Released Borough Parties, or anyone acting on behalf of the sums specified herein as Released Borough Parties, to induce execution of this Release, and that this Release is executed of its own free act. b. The Borough and its current and former councilors, mayors, officials, employees, agents, attorneys, representatives and assigns (collectively, “Releasing Borough Parties”), hereby release, discharge, and agree to hold the P&J and its owners, agents, employees, and affiliates (“Released P&J Parties”) free and harmless from and against any and all rights, claims, debts, demands, acts, agreements, liabilities, obligations, damages, costs, fees (including, without limitation, those of attorneys), expenses, actions and/or causes of action of every nature, character and description, whether known or unknown, suspected or unsuspected which are, or could have been, alleged in the Lawsuit. The Releasing Borough Parties acknowledge and agree that the Release and Discharge set forth above is a GENERAL RELEASE and shall be fully binding and a complete compromise settlement by them of matters involving disputed issues of law the Released P&J Parties and factany and all other persons, firms, or corporations who are or may be liable for claims that are or could have been asserted in the Lawsuit. Plaintiff assumes The Releasing Borough Parties expressly waive and assume the risk of any and all claims for damages which exist as of this date, but of which they do not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect their decision to enter into this Release. The Releasing Borough Parties acknowledge and agree that the facts no statement of fact or law may be other than Plaintiff believes. It is understood and agreed to opinion has been made by the parties Released P&J Parties, or anyone acting on behalf of the Released P&J Parties, to induce execution of this Release, and that this settlement Release is a compromise executed of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly deniedhis own free act.

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff Claimant hereby completely releases and forever discharges discharge Defendant and Insurer from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff Claimant now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) incident described in Recital A above, including, without limitation, any and all known or unknown claims for bodily and personal injuries to PlaintiffClaimant, or any future wrongful death claim of PlaintiffClaimant's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the Defendant. 1.2 This release and discharge shall also apply to Defendant's and Insurer's past, present and future officers, directors, stockholders, attorney'sattorneys, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliated. 1.3 This release, on the part of the PlaintiffClaimant, shall be a fully binding and complete settlement among the PlaintiffClaimant, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff Claimant acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff Claimant expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff Claimant does not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect PlaintiffClaimant's decision to enter into this Settlement Agreement. The Plaintiff Claimant further agrees that Plaintiff Claimant has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff Claimant assumes the risk that the facts or law may be other than Plaintiff Claimant believes. It is understood and agreed to by the parties that this settlement is a compromise of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly denied.

Release and Discharge. 1.1 In consideration of for the payments set forth in Section 22.0, Plaintiff hereby completely releases and forever discharges Defendant and Insurer the Defendants from any and all past, present present, or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a in tort, contract contract, or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, acquired on account of, or may in any way grow out of, or the actions of the Defendants which are the subject of the Complaint (and all related pleadings) includingComplaint, including without limitation, any and all known or unknown claims to Plaintiff, or any of Plaintiff's representatives or heirs, the Plaintiff which have allegedly resulted or may result from the alleged or acts or omissions of the Defendant. 1.2 This release and discharge shall also apply to Defendant's and Insurer's past, present and future officers, directors, stockholders, attorney's, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete settlement among the Plaintiff, the Defendant Plaintiff and the Insurer, Defendants and their heirs, assigns and successors. 1.3 In consideration of the release by the Plaintiff of their claims against the Defendants and the dismissal of their claims with prejudice, the Defendants completely release and forever discharge the Plaintiff from any and all past, present, or future claims, demands, obligations, actions, causes of action, rights, damages, costs, expenses, and compensation of any nature whatsoever, whether based in tort, contract, or other theory of recovery, which the Defendants now have or which may hereafter accrue or otherwise be acquired on account of, or may in any way grow out of, the actions of the plaintiff which are the subject of the Complaint, including without limitation, any and all known or unknown claims of the Defendants which have allegedly resulted or may result from the alleged acts or omissions of the Plaintiff. 1.4 This release, on the part of the Defendants, shall be a fully binding and complete settlement among the Defendants and the Plaintiff and their heirs, assigns and successors. 1.5 The Plaintiff acknowledges and agrees Defendants acknowledge and agree that the release and discharge set forth above is a general releaserelease as between the Plaintiff and the Defendants. The Plaintiff and Defendants expressly waives waive and assumes assume the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does and Defendants do not know or suspect to exist, as between Plaintiff and Defendants, whether through ignorance, oversight, error, negligence, negligence or otherwise, and which, if known, would materially affect Plaintiff's the decision of the Plaintiff and Defendants to enter into this Settlement Agreement. The Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law Mutual and fact. Plaintiff assumes the risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by the parties that this settlement is a compromise of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly denied.Reciprocal 2

Release and Discharge. 1.1 In consideration Subject to satisfaction of the payments set forth in Section 2terms of this Agreement, Plaintiff hereby USA Direct on its own behalf and on behalf of its past and present officers, directors, employees, agents, servants, stockholders, attorneys, representatives, insurers, subsidiaries, affiliates, and partners, predecessors, parent companies and assigns, and all other persons, firms, and corporations with whom any of the former have been or may hereafter be affiliated, completely releases and forever discharges Defendant Schoolpop and Insurer each of its past and present officers, directors, employees, agents, servants, stockholders, attorneys, representatives, insurers, subsidiaries, affiliates, and partners, predecessors, parent companies and assigns and all other persons, firms, and corporations with whom any of the former have been or are now affiliated, from any and all past or present claims, demands, obligations, actions, causes of action, rights, damages, claims for punitive damages, costs, expenses, attorneys' fees and payments of any nature whatsoever, whether based on a tort, contract or other theory of recovery that USA Direct now has, or that he, she, it or they may hereafter accrue or that he, she, it or they may otherwise acquire on account of, or that in any way arise out of any matter, cause or thing whatsoever, from the beginning of the world to the date hereof, including, but not limited to, the subject matter of the Memorandum. 1.2 Subject to satisfaction of the terms of this Agreement, Schoolpop completely release and forever discharges USA Direct from any and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, claims for punitive damages, costs, losses of servicesexpenses, expenses attorneys' fees and compensation payments of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff recovery that they now hashave, or which may hereafter accrue or otherwise be acquired, acquire on account ofof any matter, cause or may in any way grow out ofthing whatsoever, or which are from the beginning of the world to the date hereof, including, but not limited to, the subject matter of the Complaint (and all related pleadings) including, without limitation, any and all known or unknown claims to Plaintiff, or any of Plaintiff's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the DefendantMemorandum. 1.2 This release and discharge shall also apply to Defendant's and Insurer's past, present and future officers, directors, stockholders, attorney's, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, and assigns and all other persons, firms or corporations with whom any of the former have been, are now, or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete settlement among the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims for damages which exist as of this date, but of which the Plaintiff does not know or suspect to exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect Plaintiff's decision to enter into this Settlement Agreement. The Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by the parties that this settlement is a compromise of a doubtful and disputed claim, and the payments are not to be construed as an admission of liability on the part of the Defendant, by whom liability is expressly denied.

Release and Discharge. 1.1 In consideration of the payments set forth in Section 2, Plaintiff Parties hereby completely releases release and forever discharges Defendant discharge each other individually and Insurer from any each other’s officers, directors, shareholders, agents, representatives, parent, subsidiary and all past, present or future claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint (and all related pleadings) including, without limitation, any and all known or unknown claims to Plaintiff, or any of Plaintiff's representatives or heirs, which have resulted or may result from the alleged acts or omissions of the Defendant.any 1.2 This release Release of Claims shall be fully binding and discharge shall also apply to Defendant's a complete settlement among the Parties, and Insurer's their respective past, present and future officers, directors, members, stockholders, attorney'sattorneys, agents, servants, representatives, employees, subsidiaries, affiliates, partners, predecessors and successors in interest, heirs, and assigns assigns, and all other persons, firms or corporations with whom any of the former have been, are now, now or may hereafter be affiliated. 1.3 This release, on the part of the Plaintiff, shall be a fully binding The Parties acknowledge and complete settlement among the Plaintiff, the Defendant and the Insurer, and their heirs, assigns and successors. 1.4 The Plaintiff acknowledges and agrees agree that the release Release and discharge Discharge set forth above is a general releaserelease and is without limitation. Plaintiff Petitioner expressly waives and assumes the risk of any and all claims for damages Claims which exist as of this date, but of which the Plaintiff does Petitioner do not know or suspect to exist, whether through ignorance, oversight, error, negligence, negligence or otherwise, and which, if known, would materially affect Plaintiff's Petitioner’s decision to enter into this Settlement Agreement. The Plaintiff Petitioner further agrees that Plaintiff has they have accepted payment of the sums consideration and payments specified herein as a complete compromise of matters involving disputed issues of law and fact. Plaintiff Each Party assumes the risk that the facts or law may be other than Plaintiff either Party believes. It is understood and agreed to by the parties Parties that this settlement is a compromise of a doubtful disputed Claims and disputed claim, and the payments are is not to be construed as an admission of liability on the part of the Defendanteither Party, by whom liability is expressly denied. 1.4 The Parties agree that Respondent is solely responsible for any and all surface damages, environmental damages (including surface and sub-surface damages) and any other causes of action associated with the Nielsen 1-20B1. If there ever arises any action against Respondent as it is associated with the Nielsen 1-20B1, Respondent shall indemnify and hold harmless Petitioner.