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c (ou b ,vl+y 7 -1 -(z <br />400 folsNuti. <br />SETTLEMENT AGREEMENT <br />Frank Kern et al., Plaintiffs, vs. Marlin Hansen et al., <br />Defendants; Court File No. C3 -91 -3711, Tenth Judicial <br />v District, District Court of Minnesota. <br />Page 1 of 5 <br />This settlement agreement is entered into as of / 15/1r2-- <br />1r2-- <br />1991, by Frank and Donna Kern; Frederick and Pamela Gelbmann; John <br />and Linda Elliott; John and Laurie Kinneberg; Ronald and Victoria <br />Zarada; Thomas and Heidi Fitzgerald; Allen and Geraldine <br />Letourneau; and John and Gloria McLean (Plaintiffs); and Marlin H. <br />Hansen; Ronald D. Adamson, Robert R. Adamson, and City of Lino <br />Lakes (Defendants). <br />RRCITALS <br />1. In order to resolve all claims raised in the Plaintiffs' <br />Amended Complaint and all Counterclaims raised by Defendants, <br />without further expenditures of time and money, the parties have <br />agreed to enter a full settlement of these claims. <br />2: This settlement agreement expresses a full and complete <br />settlement of all claims raised in the Plaintiffs' Amended <br />Complaint and all Counterclaims raised by Defendants in the <br />following action: Frank Kern et al., Plaintiffs, vs. Marlin Hansen <br />et al., Defendants; Court File No. C3 -91 -3711, Tenth Judicial <br />District, District Court of Minnesota; and all of the pleadings and <br />filings submitted therein. It is understood by the parties that <br />this agreement does not constitute an admission or statement by any <br />party that the other party has acted wrongfully or unlawfully. <br />3. Each of the undersigned parties to this settlement <br />agreement has had ample opportunity to review the facts and law <br />relevant to any asserted or potential claims; has had the <br />opportunity to consult freely.with counsel of choice and has either <br />done' so or knowingly waived the right to do so; and has agreed to <br />this settlement knowingly and voluntarily without duress or <br />coercion from anytsource. <br />X,s Q4N #f' Swt . AGREEMENTS <br />LS <br />-���� J 1. Ronald and Robert Adamson agree not to extend Otter Lake <br />Drive beyond Oak Brook Peninsula (as depicted in the preliminary <br />.� plat map, revised 8/9/91) (Attachment A). The present cul -de -sac <br />turnar9und at the end of the existing Otter Lake Drive will remain <br />a lbbp in its current form (as depicted in the preliminary plat <br />map).' Ronald and Robert Adamson agree that no more than 5 homes <br />will be built in Oak Brook Peninsula, now or at any time within 15 <br />years of the date of this settlement agreement. Ronald and Robert <br />