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A TRUE COPY
<br />CERTIFICATION ON LAST PAGE
<br />RYAN L. BUTLER, CLERK
<br />dismissal, with prejudice, of those claims and causes of action identified in Plaintiff's Notice of Voluntary
<br />Dismissal of Claims Against Defendant, Patrick Brian Collins, Only, With Prejudice.
<br />4. No Personal Liability. IRC hereby agrees that Patrick Brian Collins shall have no personal liability for
<br />any deficiency judgment or for any money judgment or other causes of action and claims asserted
<br />personally against Patrick Brian Collins as alleged in the Complaint and any other pleadings and motions
<br />filed in the pending Action and in Counts I, II, III and IV of the Complaint. The Parties hereto including
<br />IRC as the Plaintiff acknowledge and agree that Patrick Brian Collins is not obligated or liable personally
<br />for any money judgment or Claims personally against Patrick Brian Collins as alleged in the Complaint.
<br />5. IRC Release Covenants. Indian River County, Florida, a political subdivision of the State of Florida on
<br />its own behalf and on behalf of anyone who can claim by or through Indian River County, Florida,
<br />including, without limitation, its predecessors, parent entities, subsidiaries, affiliates, insurers, successors
<br />and assigns (collectively referred to herein as the "IRC Group"), hereby forever releases and discharges
<br />Patrick Brian Collins and his estate, heirs, personal representatives, executors, agents, insurers, successors
<br />and assigns (collectively the "Patrick Collins Group"), from all demands, claims, causes of action,
<br />lawsuits, proceedings, actions, judgments, awards, interest, assessments, damages, costs, losses, injuries,
<br />fines, penalties, fees, debts, wages, compensation, commissions, benefits, reimbursements, attorney fees,
<br />expenses, liabilities and obligations of whatever kind or nature, known or unknown, at law and in equity,
<br />which the IRC Group has, had or may in the future have, against the Patrick Collins Group or which the
<br />IRC Group has incurred or may incur in the future, by reason of, relating to, arising from, in connection
<br />with, or in any way based on, each of the following: (a) facts, events, occurrences, claims, causes of action,
<br />debts, liabilities, obligations and all other matters alleged in Plaintiff's Complaint (Filing #189755027 E -
<br />Filed 01 /1 5/2024)(the "Complaint") and any amendments thereto filed or which may be filed in the above -
<br />captioned Pending Action including, without limitation, all claims and causes of action for any deficiency
<br />judgment, and as may be further alleged in any other pleadings and motions filed or which could have
<br />been filed in the Pending Action; and (b) the Property and all improvements thereto and any personal
<br />property thereon, including title thereto, any liens and encumbrances against and attaching to the Property,
<br />and any amounts due IRC relating to, in connection with, based on, or arising from the Property; and, (c)
<br />the Quit Claim Deed. Notwithstanding anything to the contrary, this release covenant and the
<br />provisions set forth in this paragraph are not intended and shall not be construed to release the
<br />Parties from their respective duties, obligations and the covenants expressly set forth in this
<br />Settlement Agreement and the Exhibits hereto.
<br />6. Amendments/Modifications. This Settlement Agreement and each provision and covenant set forth
<br />herein may be changed, modified or amended only in writing in the form of a subsequent written
<br />document or amendment, authorized and signed by all Parties hereto. This Settlement Agreement and the
<br />Agreement as modified herein and each provision and covenant set forth herein shall not be changed,
<br />modified or amended by oral agreement or understanding or any course of conduct between the Parties.
<br />7. Non -Admission. This Settlement Agreement and the execution thereof by the Parties, and any
<br />consideration provided for herein, is not intended and shall not constitute or be construed as an admission
<br />by any Party (or any such Partys agents, representatives, attorneys or employees) of any fault,
<br />wrongdoing, or liability whatsoever, or violation of any law, ordinance, agreement, obligation and duty
<br />imposed under any agreement or law or ordinance including, without limitation the facts, events and
<br />claims, and the causes of action alleged in the Complaint and all other pleadings and motions filed or
<br />which may be filed in the Pending Action. The Parties acknowledge that all such liability is expressly
<br />denied. This Settlement Agreement has been entered into by the Parties to release and compromise
<br />disputed claims as stated herein and to avoid the expense and burden of litigating in the Pending Action.
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