HomeMy WebLinkAboutPatrick McAllister Release & Hold Harmless Agreement 2019RELEASE AND HOLD HARM ESS AGREEMENT
FOR AND IN CONSIDERATION of the sum of One Million and oo/1oo Dollars
i,000,000.00), receipt of which is hereby Acknowledged, PATRICK JOHN
McALLISTER, and all of his heirs, beneficiaries, executors, administrators, successors
and assigns, insurers, personal representatives, subrogees or trustees (hereinafter
collectively referred to as "releasors"), do hereby release and forever discharge Jefferson
County, Washington, and its current and former: agencies, appointed and elected
officials, departments, agents, employees, representatives, assigns, insurers, current and
former attorneys employed by or on behalf of Jefferson County, successors, and
volunteers (hereinafter collectively referred to as "releasees"), from all claims, demands,
damages, costs and attorney's fees, expenses, liens, actions or causes of action, whether
as a result of damage to property, bodily injury or death growing out of or in any way
related to the injuries and/or damages claimed to have been received as a result of the
matters set forth in and described in the Claim for Damages submitted on or about June
20, 2019 to Jefferson County by Patrick John McAllister("the Claim"), including, but not
limited to, all damages, lawsuits, injuries, costs and attorney's fees, and expenses
resulting or to result from the Claim whether made, brought or could have been made or
brought, whether known or unknown, and whether in past, present and future.
IT IS UNDERSTOOD AND AGREED that this is a M and final release pertaining
to the above-named releasees and is in full compromise and settlement of all claims of
every nature and kind whatsoever, and releases all claims whether known or unknown,
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suspected or unsuspected.
IT IS UNDERSTOOD AND AGREED that the releasors and releasees have
specifically contemplated the possibility that injuries and/or damages of an unknown
type or extent may exist related to the Claim, and the releasors agree, for the
consideration exchanged, to assume the risk of such unknown injuries and/or damages
becoming evident in the future. The releasors and releasees expressly understand that
the facts later may turn out to be other than or different from the facts now known or
believed to be true. The releasors and releasees expressly assume the risk of such
different facts and agree that all provisions of this Agreement shall remain in all respects
effective and enforceable and not subject to termination or rescission because of any
such different facts. The releasors and releasees expressly, knowingly, and voluntarily
waive and relinquish any and all rights that they may have under any state or federal
statute which protects a settling party from releasing claims which the settling party
does not know or suspect to exist in the settling party's favor at the time of executing the
release, which if known by them must have materially affected the settlement. The
releasors and releasees understand and acknowledge the significance and consequences
of this waiver and hereby assume the risk ofany changed circumstances or facts
concerning this waiver. The releasors and releasees expressly acknowledge and agree
that this waiver extends to any claims concerning the specific matters being released,
whether or not the releasors and releasees knew or should have known about such
claims or the possibility of such claims at the time of execution ofthis release.
IT IS UNDERSTOOD AND AGREED that this settlement is a compromise of a
disputed claim, and that the payment made is not to be construed as an admission of
liability on the part ofthe party or parties hereby released, and that the said releasees
deny liability therefor, and further that such shall not be a basis for claims for
indemnity, contribution or breach of contract pursuant to any statute, common law or
agreement
IT IS UNDERSTOOD AND AGREED that the releasors and releasees shall bear
their own attorney's fees and costs related to the Claim.
THE UNDERSIGNED acknowledges that with respect to the advisability of
signing this release, he has received independent legal advice from his own counsel, is
relying on his own investigation of the facts pertaining to this release and the Claim as
he deemed necessary, desirable, or appropriate and is relying on the advice of his own
attorney.
THE UNDERSIGNED hereby declares that the terms of this settlement are for
the express purpose of precluding forever any further additional claims arising out of or
in any way connected with the Claim.
THIS RELEASE AND HOLD HARMLESS AGREEMENT contains the entire
agreement between the parties hereto, and the terms of this Release are contractual and
not a mere recital.
I have read the foregoing Release and know the contents thereof, and sign the
same as my free act and deed.
DATED thisday of ,.. , 2019.
READ BEFORE SIGNING BELOW
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trick John WcAllister
In consideration of the release tendering the settlement check and not naming as
payee the persons who or entities which may have a lien or other claim to the settlement
funds, the undersigned will defend, indemnify and hold releasees harmless against all
liens or other such claims, including, but not limited to, liens provided for under RCW
6o.44 and RCW 74.o9, and from subrogation claims of any nature, including, but not
limited to, those of the United States of America, including specifically any and all
repayment obligations owed to Medicare, Medicaid or SCRIP, and the Washington
Departments of Labor and Industries and Social and Health Services.
In further consideration of the payments set forth in the Settlement
Agreement, claimants waives their 42 U.S.C.1395y(b)(3)(A) causes of action, and
releases and forever discharges releasees and releasees' insurer from any
obligations for any claim, known or unknown, arising out of the failure of
defendants and/or defendants' insurer to provide for a primary payment or
appropriate reimbursement pursuant to 42 U.S.C. 1395Y(b)(3)(A).
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Patrick John McAllister
STATE OF WASHINGTON }
COUNTY OF }
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On this day personally appeared before me Patrick John McAllister, to me known
to be the individual described in and who executed the within and foregoing instrument,
and acknowledged that she signed the same as her free and voluntary act and deed, for
the uses and purposes therein mentioned.
GIVEN under my hand and offici 1 seal this ' day of r _, 2019.
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NO PUBLIC in and fob the State f
P„1E KNO, <<,, Washington, residing at:
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