Township Council Meeting — Agenda

the Township of West Orange, filed with the Superior Court of New Jersey, Law Division, Essex County, bearing Docket No. ESX-L-002761-19, and the appeal of that matter bearing docket number A-002287-19 (hereinafter referred to as the “Civil Action”). 2. Representation. RELEASOR represents that he has no pending OPRA requests that are outstanding or give rise to any claims against the RELEASEES. 3. Settlement Proceeds. Provided that RELEASOR has executed and returned to Trenk Isabel Siddiqi & Shahdanian OC (hereinafter referred to as “RELEASEE’S COUNSEL”), this Release and the Stipulation set forth in Paragraph 4 below, no later than thirty (30) days after the filing of the Stipulation of Dismissal with prejudice concerning the Civil Action, the RELEASEES shall deliver to Walter M. Luers, Esq., Law Offices of Walter M. Luers, LLC3, 59 Whitenack Road, Basking Ridge, New Jersey 07920 (hereinafter referred to as “RELEASOR’S COUNSEL”), a check made payable to RELEASOR in the amount of $15,000.00 (fifteen thousand dollars and zero cents) (the “SETTLEMENT PROCEEDS”) in full satisfaction of all claims against all Parties. RELEASOR and RELEASOR’S COUNSEL warrant and represent that payment to Law Offices of Walter M. Luers, LLC is authorized by RELEASOR’S COUNSEL and that this payment shall resolve all claims of counsel fees and costs by RELEASOR and RELEASOR’S COUNSEL and Cohn Lifland Pearlman Herrmann & Knopf, LLP. 4. Production of Records: Upon filing of the Stipulation of Dismissal, RELEASORS shall produce to RELEASEES unredacted copies of all of the emails that were the subject of the Civil Action. 3 RELEASOR and his counsel represent and warrant that no other law firm or attorney has a claim with regard to the matters being released herein. 2