146-26 Settlement and Release.pdf

1 146-26 RELEASE AGREEMENT This Release (“Agreement”), dated May 12, 2026 is made by and between the KIMBERLY STEELE(“PLAINTIFF”) in favor of the TOWNSHIP OF WEST ORANGE and THE GARDEN STATE MUNICIPAL JOINT INSURANCE FUND (collectively, the “TOWNSHIP”), hereinafter referred to as the “Parties.” RECITALS WHEREAS, on or around April 10, 2022, Plaintiff commenced an action against Defendant Township of West Orange and other defendants, in the Superior Court of New Jersey, Essex County, captioned, Kimberly Steele v. Township of West Orange, Mobility Coach, Inc., Edgar Moye, John Does (I-X), fictitious individuals and ABC Companies (I-X) fictitious business entities, Docket No. ESX-L-2374-23 ( hereinafter also referred to as the “LITIGATION”); and WHEREAS, on May 23, 2023, the TOWNSHIP filed an Answer, Affirmative Defenses, Third-Party Complaint, and Cross-Claims in this LITIGATION; and WHEREAS, the Parties desire to avoid the costs of continued litigation and to resolve certain claims between them subject to the terms and conditions set forth in this Agreement; and WHEREAS, on April 28, 2026, the Parties attended mediation before the Honorable Rachelle Harz, J.S.C. (Ret.) and agreed to a settlement in principle; and WHEREAS, the Agreement is subject to the approval of the Township Council; and WHEREAS, the Township Council, on May 12, 2026, authorized and approved this Agreement; NOW, THEREFORE, in consideration of the foregoing and for other good and valuable consideration, the sufficiency of which is hereby acknowledged, the Parties hereby stipulate and agree to memorialize the settlement as follows as follows: AGREEMENT 1. Effective Date. This Agreement, executed in duplicate originals, shall be effective on the date it is fully executed below and approved by the Township Council of the Township of West Orange (the “Effective Date”). 2. Settlement Amount. The TOWNSHIP agrees to pay the PLAINTIFF $250,000 within sixty (60) days of the Effective Date.