[brief] The Settlement Agreement.  [...] filed its motion for summary judgment in the Money Judgment Action on April 20, 2023.  [Pa44 at ¶ 4].  While the motion was pending, the parties negotiated the Settlement Agreement that allowed [...] to remain until October 31, 2023, whereupon it (and its Subtenant) would be required to vacate the Leased Premises.  [Pa44 at ¶¶ 5-6].  The Settlement Agreement also required [...], among other things, to: (i) remove all personal property and debris from the interior and exterior of the Leased Premises such that it is broom clean, as set forth in and required by Paragraph 31 of the Lease, on or before October 31, 2023; (ii) make monthly payments of $46,058.39 on or before July 1, August 1, September 1, and October 1, 2023, through the date of [...]’s vacation, but in no event later than October 31, 2023; (iii) execute the Consent Judgment for Possession, annexed to the Settlement Agreement as Exhibit A, and (iv) execute the Consent Money Judgment, annexed to the Settlement Agreement as Exhibit B.  [Pa49; Pa44 at ¶ 6].  Paragraph 4 of the Settlement Agreement provided that it would constitute an Event of Default if [...]: “(i) fails to make any Monthly Payment when due,… (iii) fails to timely vacate, or (iv) breaches any other settlement term,” and that “[u]pon an Event of Default, Landlord may immediately submit the Consent Judgment for Possession in the Tenancy Action and/or the Consent [Money] Judgment in the Law Division Action to the appropriate Court(s) for entry, together with a representation that such submission has been made with the consent of all Parties.  Landlord may execute upon any judgment entered thereafter without further notice or demand. ”  [Pa52 at ¶ 4].  The Settlement Agreement did not relieve or release [...] from its continuing obligations owed under the Lease.  This includes Paragraph 17 which precludes [...] from acting in violation of any environmental law, and should it do so notwithstanding such prohibition, “Tenant shall defend, indemnify and hold Landlord harmless against any [environmental] liability, loss, cost or expense, including reasonable attorneys’ fees and costs incurred by Landlord. ”  [Pa77 at ¶ 17].  By their express terms, the Settlement Agreement and Consent Monetary Judgment provide that, upon an Event of Default, the Consent Monetary Judgment may be submitted to the trial court for entry and execution in the stipulated amount of $796,484.39, not including attorneys’ fees and costs, consisting of the following amounts the parties agreed that [...] owed to [...] as of June 1, 2023: (i) Base Rent in the amount of $29,745.66; (ii) CAM Charges/ Operating Expenses in the amount of $40,338.91; (iii) Real Estate Taxes in the amount of $77,409.91; (iv) Insurance in the amount of $1,260.85; (v) Late Fees in the amount of $1,855.20; (vi) Security Deposit in the amount of $55,204.04; and (vii) Accelerated Rent in the amount of $765,260.42; less (viii) a credit in the amount of $174,590.60 (together, the “Judgment Amount”).  [Pa51 at ¶ 3(d); Pa62].  [...] not only agreed that this amount was actually and presently owed under the Lease and may be adjudicated against it upon an event of default, but also agreed that [...] may represent to the trial court that [...] had consented to the entry of the Money Judgment in that amount.  [Pa52 at ¶ 4].