Borough of CARTERET New Jersey Media Contact: Teter arareat Borough Files 15 Disci: cI Carteret, NJ —"The Borough of Carteret tay annotnead that 16 femal deeplinary charges have been leveled against several Borough firefighters. The announcement coincides with a Civil settiement by the Borough's insurance carrer regarding Itigaion conceming alleged inappropriate behavior and harasement by a few members of the Carteret Fire Department. {Although the civil iigation and the plaints failure to cooperate with the Borough's disciplinary investigation had delayed the fing of the disciplinary charges, the conclusion ofthe itigation hha allowed the Borough to move forward with charges agains fur firefighters at this time. The charges range from sexual harassment to conduct unbecoming of a public employee. The plaints now required ~ as part ofthe settlement agreement to cooperate withthe Borough In prosecuting any individuals involved in alleged misconduct “Cartoret's firefighter risk thelr lives to keep our families safe and the community's civil servants are good, hard-working people,’ stated Mayor Dan Reiman. "That is wity this Borough will not tolerate the alleged outrageous behavior of a few, who have put at risk the reputation of ‘ur Fire Deparment. The very day that these allegations were reported to my office, | immediately ordered an investigation by the fire chief and law director.” “The insurance settiement includes an approximately $685,000 payment forthe plait plus attorney’ fees and costs, Besides requting the plaints testimony at any upcoming disciplinary hearings, the settlement stipulates that the plaintiff can never again be employed by the Borough, ‘Let me be clear: The settlement of the civil legal matter does not mean thatthe Borough ‘accepts any or all claims in the inal complaint as fat, nor does it mean that all claims indeed have been substantiated,” added Mayor Reiman. Infact, tis important to note that any Individuals involved wl be afforded due process inthis matter. However, based on the Investigation to date, here appears to be evidence of behavior that is disturbing and Unacceptable ~ and there is no depariment or office inthis community where such things will be tolerated”Fax Sorver 11/26/2014 9:05:39 AM PAGE 3/018 Fax Server ‘SEXELEMENT AGREEMENT AND RELEASE ‘THE SEYTLEMENT AGREEMENT AND RELEASE (hervinaler “Agreement”) is sudo between KERRY ANN MANSURTO, her iit, representatives, sucesoors and easigns (ereinatter refered to a8 “Mansueto” oe “Plaiatif™), aud the BOROUGH OF CARTERET/ CARTERET FIRE DEPARMENT, Its present and former afiliates, elected officials, officers, diretors, agent, attomeys, employees, former employees, volunteers, representutives, end all of ‘thee successors aad assigns. (hereinafter referred to as “Carterot” or “Defenwdants") RECITALS WHEREAS, Mensoito was an employee of tho Borough of Carteret who filed st asserting claims arising out of her pert ime employment, volunteer satus and sobsequent employment, ete Mansueto v. Borough of Cartes, etal, a the New Jersey Supeior Court, {Law Division, Middlesex Vieinge, onder Docket No -$500-11.(Horsinaer “Acton” and WHEREAS, the patios to the Action have reached an agreement to filly and finally eto ll elas among them, thet were asserted or that could have been assredia the Aetion: ad. WHEREAS, none ofthe Defias inthe Aation admit Habitty or any wrongdoing of wy kind. NOW, IN CONSIDERATION of the payment to Mansueto provided for by this ‘Agreement, an other good and valuable consideration and the promises and coventnts contained hess, tho reeip and sulicency of which the patienaknowedye he parte do herby aoe a8 follows: 1, ‘Twenty-eight (28) days after receipt by Hoagland Longo Moran Dunst and weFax Server 11/26/2014 9:05:99 AM PAGE 4/018 Fax Server Dovkas LLP of the filly executed agreement by Mansucio and her counsel, the sbove Defendants, by and through thee insurance administrators, shall diver three (3) checks foe the following amounts in fll susfhction ofa chains contained inthe Compl and es developed in this Action, including toa cleima of! negligent ad Jor wrongs ass, whish alogdiy resulted in personal injury, mental anguish, pain and subing, emotional distress, medical expenses, alley ees and cost, economic loss including back py, oot poy, and lst wages, s fellows ov check wil be sued to the law frm af ro Zinaa Ciel Pars & Genitenpo, fa the amount of $407,63623 In fll ststuton of al atoms fes nd east; (0 be reported to he IRS by the Deindant andlor thei epeesentatives ot form 1099.Mise), one cack wil be issued to Gateway Counseling LLC in the amount of $2,500 in ful satisfaction ofall medical expenses snd eos (0 be epoted to the IRS bythe Defendant andr tei represevtatves on fem 1099 Mis) and one check wil be ftued to Kerry Ann Mansueto in the amount of $664,863.80 in fal nection of al luis for wage and economic loses, personal injury, emotional stress, ‘sin and suffering and al other injuries, Based upon a calculation made by Mannuot'scxtfed poblic acsoutant and at Macwost"s request allestion of the payment to Mansueto will be {$22,627.00 in fl station oF cain fr lost wages end econ loses, (1 bo eported to the IRS ty the Defendant sndfor their representatives on fxm 1099-Mis, as oorvemployee ‘compension) and $642,236.80 in fall satiefiction of all elsims for personal injury, physical and peychological injury, emotional distress, pala ao surg and al oer injure, (1 ho reported to the IRS by the dofendent and/or ther representative if deemed appliesble) . Mansueto has ‘greed with the allocation of the amouuts aud payces as sate above and his authorized the _--ghesks to be made payable as indicated and waives any claim for improper payment, and has w :Fax Sorvor 11/26/2014 9:05:39 AM PAGE 5/018 Fax Server requested that all checks to be delivered to Alan Genitempo of Piro Zina Cifeli Paris & Genitempo for distibution, The parties agree that Tax Id. and social security numbers ofthe "cipionts ofthese payments may be provided separately. 2 Paint expressly wgrec £0 cooperate fly and completly in any administra Aisciptinay investigation, proceeding or prosecution brought sgainst present or foemor employees or volunteers of the Borough of Carteret Fire Department that aie out of tho silegatons tht are pat of Mansueto's claim asserted in the ation. Her parpation in these proceedings would be atthe discretion ofthe counss forthe Borough of Carteret, but woul be linited t0 involvement that counsel dosms necessary and wil endeavor to fit Mansoeto's paticipation ifposible, Should Plaintiff determine the need foe privat counsel, she is ported to be represented, at hor own cost, in acy adminiteative investigation, proceeding or hearing. ‘Any reasonable, divest out of pocket expense andor Lost wage ieumed by Mansuoto resulting, fiom her coopertion in any administative dciptinary vestigation, proceeding or prosecution, shall be submited for review and processing tothe counsel forthe Borough of Carteret. The ‘protection of ay an all dsptinary charges ch be inthe sole and absolte discretion of the counsel for the Borough of Carteret, Mansueto acknowlodges and agres that she has uo einnding to asert any clans of any kind axsing ont of or relating tothe outcome of the investgntion, any decision to. prosecuto her chims, oF the outcome of any dissplinary proseoution afer llgations. Mansueto ackawlodges that on guanwnty ca he provided ato outcome of the prosecution of any disciplinary charges pursued through the Civil Service sciplinacy system with regacd to her allegations Gq _* Postoperative ring te covey of ia nd 2Fax Server 11/26/2014 9:08:39 AM PAGE 6/018 Fax Server dependent upan the outcome of any disciplinary prosecution which may be brought against any of the Fire Department employee witneses involved in tho 2004 investigation involving, complaints of Mansueto, coansel for the Borough of Carteret wil review and, iit is determined at sy suis wilsonses Fed dung sad investigation, amend, revise or ody Hts Hadings and determinations accordingly conceming the 2004 Investigation. Any such amendment, cevision or ‘modification of fadings stall be provided to Pio Zina CH Pars & Genter and placed i Mansucto's Borough pisonne Se 4, While a voluncer freighter, Plaintiff was a participant in the Length of Service ‘Awad Program (LOSAP), which progam was adzinisured by the Lincoln Financial Group, Pints LOSAP account was closed. Plant agress to release an discharge any claims she ns spans any Defeats othe Lincoln Finacial Group in exchange for Plait resiving a cheek, fram the Borough of Cater, based upon the proceeds fom the Lincoln Financial Gronp secountmsntined on behalf of Plan, nthe amount of $668.82 which represents the fall talmce ofthe LOSAP contibutions mde, with interest, oo behalf of or by lain: Plaintt mdertands and agroos tat by executing this Agresment and Release, sho releases and waives ny clan conoeening the LOSAP program, the LOSAP account inher name, anor the ability to re-open any LOSAP secon ot her bealf wits the Catrt Fle Department o the Borough ‘of Caneret, 5. By oncenting thi agreement, Mansaeto agroe that cho will not ood 20 smployment with the Borough of Carteret or the Carteret Fite Department andr its successor and nfiiated centes. 6 Former Fire Chiof Brian O*Connor has agreed to provide Pliotiff with a one-time @ ‘Fax Server 11/26/2014 9:08:39 AM PAGE 7/018 Fax Server eter concerning her employment withthe Borough of Carteret which Palit may Keely utliee to cain subsequent employment. Should move than sai leer be required bya prospective or fitare employee ofthe Phin, Plait may idsoify counsel forthe Borough of Caer, @ referent vine Pin explain wil the Doough of Caters. “1. The Nocough of Cateret wil exercise i best ffs to provide continued taining o all of its employees concerning harassment and dsciniaation on a biannual basa, “The implementation of si plan shall be en tinetable as dotermined by tho Borough of Crtecet and the mature snd content ofthe traning shall beat the sole and absolut discretion of the Borough ‘of Caters. Te reach o alloged bowch of the undertaking to provide soc tenning sal not be ‘basis to resind this Agreement or void the settlement. 18. The Borough takes no postion gard to any decision by the Volunoer Fie Departs with regard to the requirments of any Life Membership of Mi. Mansueto ad the ‘Voluatee Fite Company is eto make whstver deisons It determines wih regards thereto, 9. Defindante rake no representations regarding th federal or sto tx consequences of ‘he payments refered to above and shall not be rsponsble for any tax lili, Interest or penalty ncured by Mansueto, Gateway Counseting LLG, oc her counsel, whic in any way arises cout of or is related to said paynents, The paties stipulate that Plain her cerifod public sesountant and her counsel caloulated the amounts for distribution, as sot forth above: Shoald any fedora ot site taxing agency, anthoity or depurient challenge the apportionment of the total setenent amount, Mansicto and her counsel agree 19 pay any amount that may be clermined to be due and owing 28 tase, itoest and penalties wising out ofthe payments ay to in Parageaph {should it bo determined thet aif or part of such payments constitteFax Server 11/28/2014 9:05:39 AM PAGE 8/018 Fax Server ‘oss income to Manse, Gsteway Counseling LLC, and he counsel witha the meaning of te Internal Revense Code of 198, as amended, oF under any oter fer sa or local statute or crtnance, Mansueto and her counsel further agree to () bold hamless Defendants against, and to indemnity Dofendent fo, sy and all losses andor damagen arising fom clio by the Infernal Revenue Service “IRS, oF any other taxing athoriy or other governmental agency (oivethe eden, tat loca), which maybe made against Defendant arising out of of rating (0 Defendant’ fur to withhold any potion ofthe payment to Mansut fr income or social seoury tax purposes, ofr any other purpose, and (reimburse Defendants for any resulting pment, including without Hniaon ll nates nd interest pyuble othe IRS, o any thar taxing authori oF govemmental agency. Tho partes further agro that Defendants wil give ‘Mansueto and her counsel notice of any such claim, znd Mansueto and her counsel will cooperate ‘with Defendants in the defense of such claim. In any action commenced aguinst Mansueto and ber eoanset to enforce the provisions ofthis paragraph, Defendants shall be ented to recover ts attorneys? fees, costs, disbursements, and the like incurred in prosecuting the aeton. 10. By exocuting this Agroomont, Mansueto centfes that che hus complied with the requirements of NJ.S.A, 2A:17-56.23b. Plaintiff understands and agrees that the setlement amount rvfoseced in Paragraph 1 will not be rloasod until such timo as her attomey provides Defendant’ counsel with a certified copy of a child support jodyment search, performed by a peloute judgment search company, reflecting that Pali sot a child support judgment debtor. ‘A copy of the Charles Jones Report shal be aftached hereto by Plain {P's counsel as Exhibit B, 11, Pursuant to the Uniting. and Strengthening America by Providing Appropriate “Tools Required to increept and Obstruct Terrorism Act, Pub... No. 107-56, § LIGNE, US wy iFax Sorver 11/26/2014 9:05:39 AM PAGE 9/018 Fax Server Stat. 272 (2001) (the “Patiot Ac"), Executive Onder 13224 and the enforcement regulations set forth by United States Treanuy Depatments Faaaclal Crimes Enforcement Network (CFinCEN', Plaine understands and sprees thatthe setlement amount referenced fo Paragraph 1, will note rleasod unl aush ime an hor atommaye provide Couacel for Defendants with = ‘ontsied copy of a search, performed by a private scarch company, reflecting that Plants not entifed on the list Specially Designated Nationals end Blocked Persons, generate by the Ofties of Foreign Assets Contol CORAC:). Plant ther understands and ares tha inthe ‘event itis revealed thet sho is identified on the list of Spesialy Designated Nationals and Blocked Persons, gener by OFAC, se wil ot mosive any ofthe proceeds ofthe settlement without Court dee. A copy ofthe Chales Jones Report shell be attached hereto by Plans ‘coun Exhibit, 12, Plaintif acinowiedges that all clains for wages and medal expenses, paid ‘unpaid, anc/or fen asserted for wages and medical expense, ldo Unpsid, willbe satisfied fiom the proceeds ofthis seternent is aknowlegod that sere as ben a separate payment Gotonay Connnaing LLC, which payment bas been calculated by end requested by Pint, Payment for any adctional medical expeases, whether of Gateway Counseling LLC or another provider, wile satefd tom the proceeds of wy monies paid to Plain Plain? further ares that she will be responsible for reimbursement, if ny, of Meds or Media, fom the proceeds of the cetement, Ry cxceting thi ngrrment, Pint ctf he has complied ‘with th sequirements of 42 USC. §1395y, ot 9oq and 42. CHER. $411.24, tg. Should any subsequent clans be made under these subsections, Plat further agrees (o() hold humloss Defendants aginst, and to indesnnify Defendants foe, ny and all oases and/or darnages arising © ;Fax Server 11/26/2014 9:05:39 AM PAGE 10/018 Fax Server fiom claims slain to MedicaiMedicald rowpht by any goveramental ageney (whether feral, sate or local) of any eter medical provider, which maybe made aginst Defendants arising out of or relating to Defindents' failure to withhold any portion of the payment to Pitts for matical Hen purposes, oF fr any olor purpon, and (I) imbue Dafendants for any resuing payments, cling without tiitaton, ll peases nod ioterest payable to any governmental agency or medial provider. 13, The partes free epree that within fen (10) dys of the reeipt by eounse for Pi Giff of tho payments refered to in Paragraph 1 hein, a Stipulation of Dismissal sth Prejudioe as to claims against Defendants, tho Borough of Carterct and the Carteret Fike Department, shall be filed with the Cle of the New Jersey Superior Court, Law Division, Middlesex vicnage. Pint and Defendants, the Borough of Caxteret and the Caeret Fire ‘Department, agree on tho foam of the Stipulation of Dismissal of this Action, with Prejdies, ‘which attached hereto a8 Exhibit A, 14, his specifically understood and agreed thet the amount pid under this Release ‘and Agpoemen inchs all storeys fos and cost to which PlantiOT andlor he attomey(s) may te ete andthe setfement sum i peifcally intended wo be ioclusive ofall attorneys" foes snd costs. Plait andestnds that by executing thin Agreement and Relea, she releases and waives any cleen andor sight to altrneya' fees and expensos in connection with the Action. [Naithor Paint, nor the Law OBtces of Pio Ziama Ciel Pais & Genitesmpa or any other Faw lem, nor anyon> acting on their behalf, shall make an application for addtional monies in ‘addition to the amount set foah in Paragmph 1, as those amounts arw included fn the total payment being made herein, © ;Fax Server 11/26/2014 9:08:39 AM PAGE 11/018 Fax Server 15, Mansueto hereby releases and forever discharges Defendants, its present and former affiliates, elected ofMcils, officers, directors, agents, atomeys, employees, former employees, volunteers, representatives, insurers and reinsurers and all of theie suvcessors and essigns from any and ll ations, uses oF ation, site slams, charges or samples, known oF known, whieh Mansueto hes, may have, or claim to have aginst any of hem for everyting that has oseuted pw the date ofthe signing of his Agreemeot. The parties futher agree that the Defendants and their agents, representatives and assigns shall have the sole right to pursue chims ogsinst ony third party insiors for reimbursement of the setement amounts paid hereunder ind the costs and expenses incred by them 19 defend Plaintiffs claims uodor any spplicable plivies of insurance, nd ha this cetderent shall not constitute a waiver oreeaseof sich clans, Mansueto acknowledges that this is « General Release and includes bu isnot limited to claims st forth inthe Complaint and as developed in this Aston. Mansueto hereby expressly waives and releases any and sll claims or rights arising andor the New Jersey Law ‘Against Discrimination, NJ.S.A, 10:51, ef sea claims or rights arising under the New Jersey Givil Rights Aet, NULS.A. 10:6-1 gt son, claims arising under any fodera or state constitution, ‘statute oF law; Title VI of the Civil Rights Ast of 19645 dhe Age Discrivination in Employment ‘Act; the Civil Rights Act of 1991; 42. U.S.C, §1983; the Americans With Disabilities Act; the Rehabilitation Act of 1973; the Family and Medical Leave Act of 1993; the Kgual Pay Act; the [Now Jory Consciontious Employee Protection Act; the New Forsoy Family Lanue Act; the New “ersey Stale Wage ane Hour Law, all clhims arising wader any Executive Order and any clvims derived fromm or based upon any federal or state regulation; all common-law claims including, but @e limited to, wrongful dischorge, wrongful acts, negligence, public potiey violation,Fax Server 11/26/2014 9:05:39 AM PAGE 12/018 Fax Server whistleblower retaliation, breach of an express or implied contrac, treach of an implied ‘covenants of good faith and thir desing, intentionat infliction of emotional distress, negligent or inentional misrepresentaion, defamation, fraud, misrepresentation, negligent or tortious interfreice with contest or prospective esonomnle advantage al elaims for any economic Lowe lading back wages, font pay, overtime pay, finge beneis, oF aay other fm of ‘compensation; all claims for portal injury, incloding mental anguish, humiliation, pain and sufeing, emotional dswess, damage o name or reputation, o any oer form of compensatory cc puntve damages, ll claims for economic loses, inloing but not Kite lst wages, back ‘pay and font pay, and al lms for costs, expenses, and atomey’s frs and any and all thor claims however denominated, regardless of loyal thoary. This Goneral Release includes all lain, known or unknown, fr aything that has occured upto and Sachin the date of this ‘Agreement, Masato further releases any and lights she may havo to sek dtsovery on any lain which Yave been encompassed by this Iwai, or which has boen arnt ofthe esion of the Defeodans, their representatives, agents, attomeys, volunleer employee, foner oF preset closed officials, former or peseat employees. Defendants hich release and forever Aschacee Mansueto from any sal lame for allorney's foes which they may have against Mansueto, her tile, executor, administrators, suocessos andlor assigns, arising ont of this asa 16, Mansusto further cavennts and promis that she wil not hereafter file cr ease to te ied her baby char, complaint ep or acintstative aeton of any nature bate any courtor administrative agency to asset ny claim aginst Defendants o ny of the persons of centtis released herein for anything tat has occoned up to anu including the date of hisFax Sorver 11/26/2014 9:05:39 AM PAGE 19/018 Fax Server 17. This Agreement doesnot consis nd shall in no manner be const as en admssion of any wrongdoing oHabity, of violtion of any foro tate ttt, or common law rights, including those reaing to the provisions of any sw or statute concerning cuplayment actions, or of ny othr posi o claimed violation of aw or right on sh pat of Pliatif,the Borough of Catoret andlor the Carteret Fire Deprtent, ora an adiason by the oroogh of Carteret andor the Catret Fe Departnent, ofthe validity of any ofthe Pints allegations as coined inher Complain andor as supplemented during the couse o discovery dutng the course of this Acton, All Defendants continu ta maintain the validity of the denials snd aimative defenses set fort inthe Answer tothe Complaint and a sa forth a his Action, 18, The putin acknowladge the seulement of this mattor reflects desis of the aries to aeably resolve the istues disputed and tho patos expres acknowledge tat neither the setement nor any poston taken established thatthe Borough of Carteret and/or the Carteret Fre Deparment utd in & dsriminatory manner with respot to laa during her tenae as @ ‘volunteer iefightr, her employment as ape diem EMT, or thereafter. 19, Mangustorepresonts that che has not assigned to any third party any ight orca thot she has, may have or belioves she has or may have agtnst the Defendants, Mansueto roprosents thet she hes no other charge, claim or complaint of any Kind pending apsinst the ‘Defendants and sho further covenants and ropreseats that she will not file or permit any thie pay to fila any charge, claim or complaiot gaint the Defentants senking personal recovery, sanctions oF peexnal injuntive relief with respect to any matter in any way arising out of or cling to Plait involvement wit the Defendants prior fo tho date Ut thls Relowse and wr Agreement hus been executed, or any mater or fosident relating to the subject materFax Server 11/26/2014 9:05:39 AM PAGE 14/018 Fax Server of the Complaint. This representation specifically does not encompass any action taken by Borough counsel, of which Plain” would be @ cooperative witness, in accordance with inay lai, allegation of her wromloing, or igaton which may b pending oe led in the Future augsnat Borough of Caters, the Cartes ire Department, ts representatives, fomnc and presen employes, volunteer employees elected official, stomeys or agents ortho Defendants, The ities het acknowledge hat Manso may be compel to atin gation by euro ox proves 21, Inthe event any party breshos he tems and provisions se ath athe preceding paaap, thon ny other arty sal bo emt ving an action fr beach of this Agreement Irany pasty seeks to enforoe o rescind this Agenment asa result ofa breach, se oe parties wit ke ened tobe restored to the status quo ante or an order of enforcement 22, By exceuting this Agreement, Mansueto represents and acknowledges that she does ot rly, aad has nt relied upon, any represonation or stetomeat not set fot in his Agreement mado by Defendants, Borough of Carteret andor the Cartxet Fie Department or thelr ospeetve counsel with gad othe subject maser, bass or effect of this Agrosment or otherwise. This Agreement sts fort the enc agreement between tho partis and supersedes ‘any ad al prior agreements or understandings between the patie, 23, This Agroomont shall be binding upon and inure to the benefit of Mansueto and ‘the Borough of Casteret and the Cartxet Fire Department, and any of her respective het, egal e ‘pecsonal representatives, or is agents, employees, offices, elected officals, successors orFax Server 11/26/2014 9:05:39 AM PAGE 16/018 Fax Server assigns. 24, This Agreement shall be construed in accordance Wh the laws of the Sta of ‘New lersey. 25. The parties agree that the language of this Agreement has been negotsted, is a product ofthe draftsmanship ofall of the parties and that the usual rus thet the provisions of ocument are to be constr against the drafter shall not apply to the interpretation of any provisions hereof, 26, ‘The signature ofthe partes below indicates tha they have had an opportunity to roview this Agreement with their respestive ttamey() that they have read and understood the ‘provisions and that they havo executed it voluntarily with full knowlodge of the significance of al provisions. 21. ‘This Agreement may be exesuted in counterparts, each of which, when so wo and delivered, shall be deemed to be an engin, IN WITNESS WHEREOF, and intending to be leglly bound, the partes have executed this Agreement,Fax Server 11/26/2014 9:05:39 AM PAGE 16/018 Fax Server STATEMENT BY THE INDIVIDUAL WHO 18 SIGNING BELOW: ‘The Defendants have advised me in writing to conmult with #2 attorney pelar to executing this Agreement and Ralnse, have carefully read and fully understand the provinlons ofthe Agreement and Release and have had sufisient tine and opportunity (over © period of at Inast twenty-one (21) days) to consult with my personal fax, financial and legal advisors prior to execating this decutnent, and I Intend tobe Igy bound by ts ferms,_ 1 thio Agreement in executed prior tothe expiration of the twenty-one 21) day perlod vo specified, I do s0 in 8 knowing and voluntary manner with the full knowledge hat Tam walving any and all righty or elaina X may have to the Into change tho sefficlensy, scope or tera of the Agrecment and have done so after consultation with my sitorney, Kunderrtan that Tenay revoke my signature within seven (7) days follow my signing; 1 understand that my rights under this Agreement are contingent on my sigaing {hls Agreement and Retense and not revoking my signature on sad docament, @ By: eFax Server 11/26/2014 9:05:39 AM PAGE 17/018 Fax Server ‘STATE OF NEW JERSEY county oF G/4/ary 1 CERTIFY that on shutonthee _., 2014, Kenry Aon Mansueto, ‘personally came before me and acknowledged under oath, to my satisfaction, that this person: ss. (@) isnamed in and personally signed this document; and () signed, sealed, and delivered this document as her act and deed BY: om “lougland Longo Moran Dunst & Doulas, LLP Aatorney for Defendants @Fax Server 11/26/2014 9:05:39 AM PAGE 18/018 Fax Server sramoP NeW mesey 388. county ora 1 omy tet oo ms 2014 Keay Aun Mac, enon eames ry tat, tha prs (9 anand ond peeonlly algae tls documents and (©) signet sealed, ond delivered his dooument as he uct and ded, lao Pino inna CHIL Pals & Gestompe ‘Attorney for Plaats? Bisa Oamaru [vf ‘Hoagland Longo Moran Dunst & Doukns, LLP e-