242-25 Exhibit A - Settlement Agreement - WO_10-21-2025_FINAL.pdf

FINAL WHEREAS, on July 25, 2023 the Honorable Annette Scoca, Judge of the Superior Court, (“Judge Scoca”) entered a Temporary Restraining Order (the “TRO”) for the Mayor’s First OTSC in the Litigation; WHEREAS, after bricfing and argument, on or about March 19, 2024, Judge Scoca entered an Order for a Preliminary Injunction and written Opinion (the “PI Order”); WHEREAS, the Township Council filed a Motion for Leave to Appeal the PI Order which was denied; and WHEREAS, the Township Council filed a Counterclaim and Third-Party Complaint in the Litigation against the Mayor and the Trenk Parties; WHEREAS, on January 15, 2025, the Mayor filed a subsequent Order to Show Cause seeking 1) to invalidate Resolution 24-25 adopted by the Council on January 6, 2025; and 2) to enjoin the Township Council from executing a contract for the retention of Stephen E. Trimboli, Esq. from The Chilla Business Counsel, LLC as set forth in Resolution 24- 25 (“Second OTSC”); WHEREAS, on January 15, 2025 the Honorable Annette Scoca, Judge of the Superior Court, (“Judge Scoca”) entered a Temporary Restraining Order (the “TRO”) for the Second OTSC; WHEREAS, after briefing and argument, on or about March 31, 2025, Judge Scoca entered an Order denying the Township Council’s Motion to Dissolve the Temporary Restraints; WHEREAS, the parties desire to resolve this Litigation in order to avoid further expense and delay; WHEREAS, in accordance with Trenk’s letter dated January 6, 2025, Trenk will retire from his position as Township Attorney effective upon (i) approval and execution of this Agreement and (ii) appointment by the Mayor and approval of the Township Council of a new Township Attorney (the “Resignation Date”);