Township Council Meeting — Packet

SETTLEMENT AND MUTUAL RELEASE THIS RELEASE, dated _________________, is given BY: the TOWNSHIP OF WEST ORANGE, TO: Ron Jolyn Realty & P S Realty referred to as “You” or “RON JOLYN”. If more than one person signs this Release, “I” shall mean each person who signs this Release. 1. Mutual Release. The TOWNSHIP OF WEST ORANGE and RON JOLYN (collectively, the “Parties”) release and give up any and all claims and rights which the Parties may have against each other. This releases all claims, including those of which the TOWNSHIP OF WEST ORANGE and/or RON JOLYN are not aware and those not mentioned in this Release. This Release applies to claims resulting from anything which has happened up to now. This release encompasses releases of all clams, cross claims, counterclaims, rights to subrogation, and indemnification between TOWNSHIP OF WEST ORANGE and RON JOLYN in all pending litigations including the claims made in ESX-L-2711-23. TOWNSHIP OF WEST ORANGE specifically releases the following claims: Any and all claims arising out of the alleged incidents that occurred on or about September and October 2021, which are the subject of a lawsuit presently pending in the Superior Court of New Jersey, Law Division, Essex County, matter of West Orange v. Ron Jolyn Realty, et al., Docket No. ESX-L-002518-22 and which shall be dismissed with prejudice. The TOWNSHIP OF WEST ORANGE, on its own behalf, and on behalf of each of their past, present and future officers, office holders, employees, representatives, attorneys, agents, and/or assigns of all the foregoing (collectively, for the purposes of this Paragraph, the “Releasors”) hereby fully, finally and forever release and discharge Ron Jolyn Realty & PS Realty as well as each of its past, present and future insurers, reinsurers, officers, directors, stockholders, attorneys, agents, servants, representatives, employees, subsidiaries, parent companies, related and affiliated companies, holding companies, partners, privies, predecessors, successors in interest, and assigns (collectively, for the purposes of this paragraph, the “Releasees”) from any and all claims, demands, causes of action, damages, costs, and compensation of any nature whatsoever including but not limited to all fines and penalties, whether known or unknown, which the Releasors had, now have, or which may hereafter accrue or which the Releasors may otherwise

nature whatsoever including but not limited to all fines and penalties, whether known or unknown, which the Releasors had, now have, or which may hereafter accrue or which the Releasors may otherwise hereafter acquire, that relate to, arise out of, or in any way concern the conduct and acts of Releasee