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2. Defendant City agrees to stipulate to dismiss with prejudice all counterclaims they <br /> <br /> have brought or could have brought relating to the above-described Property. <br /> 3. Defendant City agrees to make aone-time payment to Plaintiff Valor in the <br /> amount of $20,000 receipt of which is hereby acknowledged by Plaintiff. <br /> 4. All parties to this agreement hereby agree to release in full and final fashion all <br /> claims they have asserted, might have asserted, or would be able to assert arising from events <br /> occurring up to the date the Agreement is executed, arising out of, or in connection with the <br /> Property. This general release extends to all parties and all of their respective employees, elected <br /> officials, agents, members, volunteers, representatives, attorneys, insurers, indemnitors, and <br /> successors for any and all claims, whether known or unknown, demands, obligations, actions, or <br /> causes of action, at law or in equity which are associated with the Property, whether arising by <br /> statute, common law, or otherwise, and for all claims for damages, of whatever kind or nature, <br /> and for all claims for attorney's fees, costs and expenses. This release includes, without limiting <br /> the generality of the foregoing, actions and appeals under the Minnesota and United States <br /> Constitution; Minn. Stat. § 462.355; Minn. Stat. Ch. 586; Minn. Stat. § 15.99; or any federal, <br /> state or local statute or regixlation regarding the consideration and action by a municipality of a <br /> land use or planning proposal. The parties agree to release only claims arising out of events <br /> occurring up to the date this Agreement is executed. <br /> S. In consideration of the foregoing, the parties hereby stipulate and agree that each <br /> party to this Agreement shall bear all of its own costs and fees associated with this matter and <br /> release the other from claims for costs, fees, and sanctions pursuant to the Rules of Civil <br /> Procedure to the extent that they may exist; further, the parties authorize their respective counsel <br /> to sign a Stipulation of Dismissal with Prejudice in the form attached hereto. <br /> 2 <br /> <br />