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Page - 2 <br />After thorough investigation of the claim of the Claimants, <br />the parties deem it in their mutual interests to settle and resolve <br />said claim without intervention of Court or Jury. <br />NOW, THEREFORE, the parties agree upon the following terms <br />and conditions: <br />1. The Board agrees to pay to the Claimants, the sum of <br />Twenty Two Thousand Five Hundred Dollars ($22,500.00) as a full <br />and complete release and settlement of all claims or causes of <br />action by the Claimants or either of them against the City of <br />South Bend or its agents or employees. <br />2. In consideration of the execution of this agreement, <br />by the Board, and its ratification and approval by the Common <br />Council of the City of South Bend, Indiana, the Claimants and <br />either of them agree to and do hereby forever forgive, discharge <br />and release any and all claims which the Claimants or either of <br />them may presently have or which they may subsequently or here- <br />after have, against the City of South Bend, its agents and em- <br />ployees, which said claims or causes of action arose out of or <br />-which may later arise out of a certain collision which occurred <br />at the corner of Carroll and Ewing Streets in the City of South <br />Bend, Indiana, on or about the 5th day of August, 1967, more par- <br />ticularly described in the recitation at the commencement of this <br />Agreement. <br />3. This Agreement shall be binding upon the City of South <br />Bend, its Board of Works and Common Council and upon Claimants when <br />and after it has been formally adopted and approved by the Board <br />of Works of the City of South Bend and by ordinance adopted and <br />