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

FINAL Notwithstanding the foregoing, any party may seck to enforce the provisions of this Agreement herein. 3. QGUTSTANDING FEES/EXPENSES TO BE PAID: The Township agrees to pay the Trenk Parties any and all outstanding legal fees and expenses that have been accrued, or which will in the future accrue subject to the terms of this Agreement and the Township’s right to review such fees and expenses consistent with applicable law. To the extent that the Township or the Council fails to approve and pay such fees and expenses to the Trenk Parties within sixty (60) days of the Trenk Parties’ submission of detailed invoices consistent with past practices, the parties agree that upon letter application, without necessity of a formal motion, and upon submission of each parties’ position, Judge Scoca shall make a final determination as to the reasonableness of the fees and expenses. Judge Scoca’s determination shall be binding on all the parties, final and non-appealable, In the event that Judge Scoca is unavailable, then the Judge who is designated for this Litigation shall handle these matters in accordance herewith. The Trenk Parties fully preserve all rights to be paid for all fees and expenses from the Garden State Joint Insurance Fund. 4, MUTUAL RELEASES: (a) The Trenk Parties’ Release. The Trenk Parties, in exchange for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, by this release, does for itself, its past and present affiliates, subsidiaries, owners, officers, directors, employees, heirs, executors, agents, representatives, administrators, insurers, attorneys, successors and assigns, hereby remise, release and forever discharge the Township Parties (including Mayor Susan McCartney in her capacity as Mayor and individually, and the Township Council collectively, in their capacity as Councilmembers and individually), and their respective past and present board members, owners, members, officers, directors, employees, agents, representatives,