CONDEMNATION SETTLEMENT AGREEMENT AND RELEASE
<br />This Settlement Agreement and Release (the "Settlement Agreement") is made and entered
<br />into as of "U 2020 ("Effective Date"), by and between Christopher J. Voros &
<br />Jennifer N. Morse-Voros Revocable Trust, Christopher J. Voros & Jennifer N. Morse-Voros as
<br />Trustees ( hereinafter referred to as the "Voros Trust"), and the City of South Bend, Indiana, by and
<br />through its Board of Public Works ( "the City"), each a Party and collectively the Parties.
<br />Recitals
<br />The Parties desire to enter into this Settlement Agreement in order to avoid litigation and to
<br />provide for certain payments to the Voros Trust in full settlement and discharge of all claims which
<br />the Voros Trust may have against the City in damages arising from the City's acquisition of a
<br />permanent easement and a temporary easement over the following real estate owned by the Voros
<br />Trust (the "Property"), as more particularly described and depicted in Exhibit A, incorporated herein
<br />by reference: el
<br />Property near 5810 Magnolia Road
<br />Tax Key No. 017-1012-031904
<br />Agreement
<br />The Parties agree as follows:
<br />1.0 Release and Discharge
<br />1.1 In consideration of the payment set forth in Section 2 of this Settlement Agreement,
<br />the Voros Trust (including, its representatives, agents, heirs, assigns, and successors) hereby
<br />completely releases and forever discharges the City from any and all past, present or future claims,
<br />demands, obligations, actions, causes of action, rights, damages, costs, losses or services, expenses and
<br />compensation of any nature whatsoever, which the Voros Trust now has, or which may hereafter
<br />accrue or otherwise be acquired, on account of , or may in any way grow out of the circumstances
<br />described in Recital above.
<br />1.2 This release and discharge shall also apply to and bind the Voros Trust's past, present,
<br />and future officers, employees, trustees, agents, partners, representatives, attorneys, parent and
<br />affiliated entities, subsidiaries, divisions, joint ventures, predecessors, successors, beneficiaries,
<br />companies, grantees, vendees, transferees, and assigns and any and all related corporations, companies
<br />or subdivisions.
<br />1.3 This release and discharge, on the part of the Voros Trust, shall be a fully binding and
<br />complete settlement among the Voros Trust and the City, and their representatives, agents, heirs,
<br />assigns, and successors.
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