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Home My WebLink About1996-224 Settlement Agrmt - Rydbom HOFFMAN, HART & WAGNER Attorneys at Law TWENTIETH FLOOR 1000 S.W. BROADWAY, PORTLAND, OREGON 97205 503/222-4499 FAX 503/222-2301 Michael D. Hoffman* John E. Hart Mark H. Wagner James P. Martin* David K. Miller Robert S. Wagner* Janet M. Schroer Delbert J. Brenneman Brian M. Perko Ruth J. Hooper Jeffrey R. Street* Martha J. Hodgkinson Kenneth D. Renner Dennis S. Reese William G. Adams- West H. Campbell- Lawrence P. Blunck Gordon L. Welborne Lory R. Lybeck* Connie Elkins McKelvey Lisa C. Brown James P. Murphy- Steven A. Kraemer David E. Pra~e Stephen R. Rasmussen*- Michael R. Fendall Scott Bellows- Sara H. Matarazzo Richan! L. Fortner Robert E. Kabacy* Michael J. Wiswall* · Admitted in Oregon & Washington - Admitted in Washington - Also admitted in California May 17, 1996 Mr. Paul Nolte City Attorney City of Ashland 20 E Main Street Ashland, Oregon 97520 Re: Rydbom v. City of Ashland Our File No. 2883 Dear Paul: Gordon J. Evans David S. Mepham* Margaret A. Toole. Wendy J. Paris Janet A. KIapstein Christopher L. Thayer- David C. Lewis Mark E. Olmsted. Gary R. Johnson Troy S. Bundy Legal Assistants Martha J. Gold Evelyn J. Kelley Sandra M. Morris Tamara J. Collan! Carol V. Thayer In closing out our file on the above matter, I realized that you had not received the originally signed Settlement Agreement. Therefore, I enclose the original at this time and I have kept a copy for our file. If you have any questions, please don't hesitate to call. Very truly yours, JPM:db Enclosure 11 UJ I~Jo THIS IS A CONTRACT - READ IT BEFORE SIGNING! COMPLETE RELEASE AND FULL SATISFACTION BY COMPROMISE 1 . In consideration of the paYment to me of Five Thousand, Nine Hundred, Thirty-Five Dollars ($5,935.00), I, Michael Rydbom, forever release and discharge the City of Ashland and any and all persons or entities in interest with them, of and from any and all claims for costs and attorney fees which are connected or related in any way with the incidents and allegations set forth in that certain lawsuit filed on my behalf in the United States District Court of the State of Oregon entitled Michael Rydbom v. City of Ashland; Case No. 94-3042-CO. 2 . I enter into this Release and Settlement with full knowledge of the situation at hand and under advice of counsel. I understand that this settlement is intended to entirely conclude my claims in the above lawsuit once and for all. 3 . This Release and Settlement shall operate for the benefit of the City of Ashland and their respective agents and employees, all those in interest with them, their personal representatives, successors, assigns, insurers and attorneys. 4. I agree that I am not a prevailing party as that term is defined or interpreted in any statute providing for the 1 - COMPLETE RELEASE AND FULL SATISFACTION BY COMPROMISE recovery of costs and attorney fees, and that no further attorney fees are recoverable by me. 5. I HAVE COMPLETELY READ THIS DOCUMENT AND ITS EFFECTS HAVE BEEN FULLY EXPLAINED TO ME BY MY ATTORNEY. I FULLY UNDERSTAND AND VOLUNTARILY ACCEPT THE BENEFITS, RISKS AND OBLIGATIONS OF THIS CONTRACT. STATE OF OREGON ) )ss. County of VacJ(5U'l ) DATED this iff day of !10()Crnbev' , 1995. ...~~ / (~d~ M~l Rydb m SUBSCRIBED AND SWORN 1995. day of c,~:}~r%~~;i;f~:~l~~i, ri.\: CO~Hl'1iSS::f; EXPiRES fiDV. iI. \89;J FO OREGON Expires: {(./ J. Q8' As legal counsel for the parties executing this document, and in consideration of being a joint payee on the settlement check, I enter into this agreement as to the content and provisions of paragraph 5 and agree to see that any and all expenses, bills, claims or liens, medical or otherwise, past or future, subrogate or direct, regarding services furnished to my clients, have been or will be paid or satisfied to the end that the released parties are held harmless and indemnified against any and all such claims. DATED this cfCf day of (JOU'Cmber I 1995. ,It[ II ?----- Kurt H. Knudsen SUBSCRIBED AND U~~ 1995. p[~~r;~'}~\41~i~!RY NnT\;-~Y ;~)1;S~!C nri[l~~)\j c O;\'iii-/j l;:~~-S ~ ('.~ j\j r'~ i) I J ~id !.~ ~.~ D MY CUMi~:SjiG~ F.XF;r1E;~ MQV. i L t3:~J 2 - COMPLETE RELEASE AND FULL SATISFACTION BY COMPROMISE