ETTLEMENT ir Tha Stement Agreement and Release ("A greement” i eatered ino by Kren S. Brown ("Brown") andthe City of Columbus, Idan Plioe Depertent ("CPD"), Brown ood (CRD are refered i co lovely herein as th "Pig" The EfTectve Date ofthis Agreement (he tntet date a signsize is sfc by the Panties below. RECITALS ‘A. On Febuary 17,2017, room brougt lawsuit against CPD, pendiagin {he Bartholomew Cow Superior Court undar Cue No, O2D02-1112-PL-000970 Gee “Laws loging at CPD bad violated Indian's Acces to Pabic Records Act CAPRA, B, _Alerdenving Brova’s Motion for Summary Fgment, the Court eterd Saal judge inher fever on Jano 17,2018. The Cour lao crdered CPD to py Browne "easonible attomey’s fs, court cost, and expansce Tae Cou eeined to aac any cell penalty against CPD, . The yates agree that resolving the matter witha futher ligation isin the Dest intees of he Cons taxpayers ‘AGREEMENT AND RELEASE Jn consdeoion ofthe maa promises inthis Ascent, the Pastis age {allows 1, CRD shall pay dhe sum of £32,000 in fl stisfcton of any eli under Inns Code § 5143-5) or oer eplicabl authority fr akionoys fees court cots, ane ‘penses Brown incurs in the Laws. Payent shall be me to Filleswarkh Denaerline Groth & Towe, LL? win 30 dageofthe Efotve Due, 2. eles of CPD, Brown, on behalf of herself nd any agents, atoreys, ployee, representatives, assigns, and al others ating or putporting to atone baal ‘hereby releases and fore cacharges te CPD ants ages, representatives atomere, ‘xuployoes, assigns, and al oles acting ox porporting oat on ts baal: Bom lenges, demands rights, and ate of ation relate! to het cightor cam atone es, 24 cots, or expenses led to her Lava az her Septambir 8, 2016 APRA sequen, wheter ‘novin or unmown, that have accrued or otherwise may exist sof the Eetive Dut 3. __Dismisaa of Lawsuit, Brown sal notify the Cou within 5 days ofthe Effective Date thatthe Ligation is conchuded wit he Pate o bees he own cons atornegy? ‘hes, and expenses except as hare act ft in his Agreeman 4. _Dismist! of Appeal. ‘The partis shall ie the alached Agreed Motion ‘Dismiss Appeal fom Fan Jaren within 5 dee af the Bfoctive Date with each of tno Pos ‘bet its ova ents aereys” foes snd expenoh except as cervise et arth in thisAgreeieat, 5. his Agrsment is intnded by tho Partie hereto to be s complete ‘iterated statement oF ll syrosnentsbetwoun them sad tothe gubjes mar of ths ‘Agreement, nd at oreland ott negotasions od eepresentitions leading iat ts Agrmment ‘xo merged ino this Agreement sad inesrata herein. No waver, modifeation ot meade! Of any tem o provision of hin Agreement, in whole o in par shal be vad binding er have any ‘ores or effet unless mae ia wtng and signod by he Partin, 5. Tae Agroament may be executed by counters, Copies ofthe executed Agtoements wits the Pantie signatures may be exchange elocronealy and those cote il HGh ond together constine the origi greene 3. _The Fares have no lied upon any ceposctstions, prose, ot sgrouments of ny kind made to thom in coasecton wih this agpeemans seo ine he sposfcly inluded or referenced in his Agreement 8, The ters ad conditions ofthe Agreement shall be binding upon and ‘more to tbe benefit ofthe eis, personal represatatives, lp epresenaves, sco, and assign of each ofthe Pais, 9. gts Asreament sll be governed by Indiana ies, without regard to eat of law principe. Any dgpue hereunder hall be decided by the Bartholomew County, {adiana Supesior Cou ack Party hereto hte submis othe urisition of sad eat fr tos Buposes of esolving an digrutos ewe. This Agreerent ll be construc a inepted ‘8sFal ofthe petos hersio have had an agua und ir shang ls Asooinen ane eae interpreting document gaint he drafter shal nc ppl. 4, Siouldony clause, portion, o paragraph of this Agreement be decal by ‘ay cout of competent jrssction to be unenforceable, avai olga fr any reason, ach ‘senfrceabil, invaliiy or egal bil nt aff the enforceability or eal of ‘he reainder ofthe Agrisment, slong asthe enone ed legal ubatancscomtanpled to ‘he Aproement isnot afte in uny manner marly averse fo say of ne Pate, ‘The Paes have executed ths Sstdoment Agreement ene Releese on tho dates provided blow,= [KRISTEN fc BROWN: pee Avgust 12, 20% Ics Bo rritot:_ Kersten S. Brown cxvvon gots rrgesbenaxneenr vue August” 9.2019 o Celan Zoltet