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<br />, <br /> <br />,. <br /> <br />e <br /> <br />. <br /> <br />. <br /> <br />SETTLEMENT AGREEMENT AND PARTIAL RELEASE <br /> <br />I. <br />RELEASE: <br /> <br />PARTIES TO THE SETTLEMENT AGREEMENT AND PARTIAL <br /> <br />ll1is Settlement Agreement and Partial Release is entered into by and between the City of <br /> <br />Arden Hills ("the City"), Pete's Water and Sewer, Inc, ("Pete's") and General Casualty Company <br /> <br />of Wisconsin ("General Casualty"). <br /> <br />2. RECITALS: <br /> <br />WHEREAS, the City has made claim against Rochon Corporation ("Rochon") for damages <br /> <br />arising out of the construction of a new City Hall; and <br /> <br />WHEREAS, as part of the City's contract with Rochon, Rochon subcontracted underground <br /> <br />utility work to Pete's; and <br /> <br />WHEREAS, the City has asserted a claim against Rochon for work performed by Pete's, <br /> <br />in the AAA Arbitration; and <br />WHEREAS, the City retained Collins Electrical Systems for signal loop repairs alleged to <br /> <br />have pertained to Pete's work pursuant to subcontract for traffic signal loops at Highway 96 and <br /> <br />Hamline A venue, in Arden Hills; and <br /> <br />WHEREAS, Rochon has tendered its defense to Pete's and General Casualty, which has <br /> <br />been rejected by them; and <br /> <br />WHEREAS, Pete's and General Casualty deny any obligation to defend and/or indemnify <br /> <br />Rochon because Pete's alleges and claims it did not "damage" any property of the City in its work <br /> <br />as a subcontractor of Rochon; and <br />