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<br />under 42 V.S.C. § 1983 from the City and Liner. Defendant denies all of Plaintiffs
<br />allegations.
<br />Because a dispute exists between the Plaintiff, the City, and Liner regarding
<br />liability, and solely in order to keep the peace and avoid the expense of litigation,
<br />Plaintiff, the City, and Liner now desire to compromise and settle any and all claims
<br />which the parties have or may have in the future arising out of Plaintiffs former
<br />employment with the City and/or the facts alleged in Cause Nos. 96-0953 and
<br />96-CA-706-SS, and intend that the full terms and conditions of their compromise
<br />settlement be set forth in this Compromise, Settlement and Release Agreement.
<br />COVENANTS
<br />In consideration of the mutual promises and covenants in this Agreement, the
<br />receipt of which is acknowledged, Plaintiff, the City, and Liner, each for themselves,
<br />their predecessors, successors, assigns, heirs, executors, administrators, agents,
<br />employees, and legal representatives, agree to release and forever discharge the other
<br />party, and each of their respective predecessors, successors, assigns, heirs, executors,
<br />administrators, elected officials, appointed officials, agents, directors, officers,
<br />affiliates, employees, past and present, legal representatives, and all persons, natural
<br />or corporate, in privity with them or any of them, from any and all claims, demands,
<br />damages, actions, causes of action, or suits in equity, at common law, statutory, or
<br />of whatsoever kind or nature, whether heretofore or hereafter accruing, or whether
<br />now known or not known to the parties, for or because of any matter or thing done,
<br />omitted, or suffered to be done by the City, Liner, the City's administrators, elected
<br />officials, appointed officials, legal representatives, directors, officers, affiliates or
<br />Compromise, Settlement and Release Agreement Page 2
<br />f-89707.1
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