sel ill

WHITE, plaintiff

Aad

Address

Date of bisth: pie $
*SSN:_ _
EDWARD T. STEIN *
Attorney for plaintiff

200 South Michigan Avenue
Room 1240

Chicago, Mlinois 60604

(312) 786-0200
Attorney No. ATILOUG

DATE: Aral Gi r003

*Providing SSN is voluntary

City of Chicago
a Municipal Corporation
Mara S. Georges

Corporation Counsel
Altorney for City of Chicago Address:

77

BY

ALEC M, McAUSLAND
Assistant Corporation Counsel
30 North LaSalle Street

Suite 900

Chicago, Ulinois 60602
(312) 744-2836

Attorney No, (620 734
DATE:

SHERI H. MECKLENBURG

Assistant Corporation Counsel

Attomey for defendants Coleman, Regan,
Marjian and Wallace

30 North LaSalle Street

Suite 900

Chicago, Illinois 60602

(312) 744-6905

Attorney No. 06183793

DATE: Dae _



jointly and severally, and the heirs, executors, administrators, personal representatives,
successors, and assigns of each.

10. This Release and Settlement Agreement is entered into in the State of Illinois and
shall be construed and interpreted in accordance with its laws. Terms contained hercin shall not
be construed against a parly merely because that party is or was the principal drafter.

11. Inentering into this Release and Settlement Agrecment, plaintiff represents that
she has relied upon the advice of her attorney, who is the attorney of her own choice, and that the
terms of this Release and Settlement Agreement have been interpreted, completely read and
explained to her by her attorney, and that those terms are fully understood and voluntarily
accepted by plaintiff. Plaintilf also represents and warrants that no other person ot entity has or
has had any interest in the claims or causes of action referred to herein, that she and her attorney
have the sole right and exclusive authority to execute this Release and Settlement Agreement and
teceive the sums specified herein, and that they have not sold, assigned, transferred, conveyed, or
otherwise disposed of any of the claims or causes of action referred to herein.

12. All parties agree to cooperate fully and to execute a Stipulation to Dismiss and
any and all supplementary documents and to take all additional actions which are consistent with
and which may be necessary or appropriate to give [ull force and effect to the basic terms and

intent of this Release and Settlement Agrcement.

CONTINUED TO NEXT PAGE FOR SIGNATURES



ir
IN THE UNITED STATES DISTRICT COURT ws I, Ry L

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION Aen 7 2n
103
. MAGic
GWENDOLYN WHITE, ) GI8Te
Mi TATE
) ORTON 5 SE NeoGE
Plaintiff, ) 02 € 3690 Low
) 4
v. ) JUDGE ANDERS,
) :
CITY OF CHICAGO, a municipal corporation, )

OFFICER. RONALD COLEMAN, Star No. 05922, ) ral
OFFICER JOSHUA WALLACE, Star No. 16916, ) yw ANS
OFFICER DANE MARIJAN, Star No. 10173, and) pre 41

OFFICER JACQUELIN REGAN, Star No. 13079) o
) .
Defendants. ) _~ oe

RELEASE AND SETTLEMENT AQ@EEMENT

Plaintiff Gwendolyn White, by her attorney, Edward T. Stein, and the defendant City of
Chicago, by its attorney, Mara §. Georges, Corporation Counsel of the City of Chicago, and
defendants Ronald Coleman, Joshua Wallace, Dane Marijan and Jacqueline Regan, by their
attorncy, Sheri H, Mecklenburg, Assistant Corporation Counsel of the City of Chicago, herein
stipulate and agree to the following:

1. This action has been brought by Plaintiff Gwendolyn White against defendants
Ronald Coleman, Joshua Wallace, Dane Marjan, Jacqueline Regan and the City of Chicago, and
makes certain allegations contained in plaintiff's complaint.

2. Defendants deny each and every allegation of wrongdoing as stated in plaintiffs
amended complaint, and, further, deny liability.

3. The parties and their respective attorneys acknowledge that settlement of this
claim is not an admission of liability, or of unconstitutional or illegal conduct by or on the part of

any defendant and/or the City of Chicago’s future, current or former officers, agents and

AXA



employecs, and shall not serve as evidence or notice of any wrongdoing by or on the part of any
defendant and/or the City of Chicago’s future, current or former officers, agents and employces.
The partics and their respective attorneys further acknowledge that settlement is made to avoid
the uncertainty of the outcome of litigation and the expense in time and money of further
litigation and for the purpose of judicial cconomy. Plaintiff and her attorney agree that they or
any firm with which said attorney is affiliated or with which said attomey may later become
affiliated shall not use this settlement as notice of misconduct on the part of any defendant and/or
the City of Chicago's future, current or former officers, agents and employces, or for any other
purpose in any other litigation, and that any such use is inconsistent with the terms of this
Release and Settlement Agreement.

4. Tn consideration of the hereinafter indicated settlement entered pursuant to this
Release and Settlement Agrecment, and upon advice of counsel, plaintiff Gwendolyn White,
agrees to dismiss with prejudice all of her claims against defendants, City of Chicago and Ronald
Coleman, Joshua Wallace, Dane Marijan and Jacqueline Regan, with each side bearing its own
costs and attorneys’ fees.

5. Plaintiff Gwendolyn White accepts a setilement from defendant, City of Chicago,
in the total amount of THIRI'Y THOUSAND AND NO/100 ($30,000.00) DOLLARS, with each
side bearing its own costs and attorneys” fees.

6. The City of Chicago agrees to pay plaintiff the total settlement amount within
sixty (60) days after receipt by the Corporation Counsel's Office of a file-stamped copy of the
Agreed Order of Dismissal. This sum shall be payable solely by the City of Chicago, and

plaintiff and/or her attorncy agree that they will not seek payment from any source other than the


City of Chicago. The settlement check will be made payable to plaintiff, her attorney, and lien
claimants, if any, of which the City has notice.

7. In consideration of this settlement entered pursuant to this Release and Settlement
Agreement, and upon advice of counsel, plaintiff agrees to indemnify and hold harmless the City
of Chicago, and its future, current, or former officers, agents and employees including, but not
limited to, the individual defendants Ronald Coleman, J oshua Wallace, Dane Marijan and
Jacqueline Regan, from any claims, losses, damages or expenses, including attorneys’ fecs and
costs, incurred, or which may be incurred, by reason of any lien or any other claim or interest
held by any person, entity or corporation against any moneys received or to be received by
plaintiff under this settlement entered pursuant to this Release and Settlement Agreement.

8. Plaintiff, upon advice of counsel, understands and agrees that in consideration of
the settlement entered pursuant to this Release and Settlement Agreement, plaintiff docs hereby
release and forever discharge on behalf of herself and her heirs, executors, administrators and
assigns, all claims she had or has against the individual defendants Ronald Coleman, Joshua
Wallace, Dane Marijan and Jacqueline Regan, and the City of Chicago, and its future, current or
former officers, agents and employees, including but not limited to all claims she had, has or may
have in the future, under Jooal, state, or federal law, arising either directly or indirectly out of the
incident which was the basis of this litigation, and that such release and discharge also is
applicable to any and all unnamed and/or unserved defendants.

9. This Release and Settlement Agreement and any documents that may be executed
under paragraph 12 hercin contain the entire agreement between the parties with regard to the

settlement of this action, and shall be binding upon and inure to the benefit of the parties hereto,