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SETTLEMENT AGREEMENT <br />This SETTLEMEI�T"I' AGREEMENT ("Agreement") is made by and between Paul <br />Romanowski, Janet Romanowski, and Joel Cheney (collectively "Plaintiffs"), and <br />Jonathan B. Forman as the Personal Representativeof the Wallace R. �`az�.an Estate and <br />Nancy Jo Keay (collectively the "�orn�an Parties"), and the City of Roseville <br />("Roseville") to compromise, settle and resolve all controversies and disputes between <br />and among (a) Plaintiffs and the Fortnan Parties, and (b) Plaintiffs and Roseville <br />concerning real property owned by the Forranan Parties located on County Road B West <br />within Roseville on this 9th day of May, 2006 ("Effective Date"). <br />Recitals: <br />WHEREAS, the For�a�an Parties own real estate located on County Road B West within <br />Roseville and such real estate has been approved for subdivision by Roseville (the "Real <br />Estate"); <br />WHEREAS, on March 13, 2006, Plaintiffs initiated and began a lawsuit in Ramsey <br />County, Minnesota concerning the Real Estate and its subdivision, said lawsuit bearing <br />the caption Paul Rarrrnnawski, Janet Romanawski and Joel Cheney v. City of Roseville, <br />Jonathan B. Forrnan as the Personal Representative of the Wallace R_ Forman Estate, <br />and Nancy Jo Keay, Ramsey County Court File No. C2-06-2409 (the "Litigation"); <br />WHEREAS, on March 14,2006, Plaintiffs caused a Notice of Lis �'en�ens to be filed and <br />recorded against the Real Estate (the "Lis �'ext[le�ts"); � <br />WHEREAS, on March 31,2006, the Farman Parties moved to dismiss Plaintiffs' claims <br />asserted in the Litigation; <br />WHEREAS, on April 14, 2006, Plaintiffs discharged and released a certain parcel of the <br />Real Estate from the Lis �'endens, but the Lis Pendens otherwise remains filed and <br />recorded against the Real Estate; and <br />WHEREAS, on April 14, 2006, Roseville filed an answer denying Plaintiffs' claims <br />asserted in the Litigation. <br />NOW, THEREFORE, in considera�ion of the foregoing recitals, which are incorporated <br />in and are an integral part of this Settlement Agreement, and other good and valuable <br />consideration which the parties hereto acknowledge and agree is sufficient, including the <br />terms of this Agreement as des�bed more specifically below, the parties hereto hereby <br />stipulate and agree as follows: <br />l. Incort�orafiion of Recitals. The recitals above are integral hereto and <br />incorporated herein by this reference. <br />2. Release B..v Plaintiffs. Plaintiffs, on their own behalf and on behalf of <br />their agents, successors and assigns, hereby release and discharge the <br />