and which may be necessary or appropriate to give full force and effect to the basic terms and

intent of this Release.and Settlement Agreement.

Thomas Conrad, plaintiff

Address: /20Z%3..5 SF se
OAK LAwy BY:

Date of birth: 3° -JO-5 @

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30 North LaSalle Street
Suite 2140

Chicago, Illinois 60602
(312) 580-1830.
Attorney No...

DATE: LO i 410 ¢

City of Chicago
a Municipal Corporation

Mara S. Georges
Corporation Counsel

AN, ioe

Jef Give ww)
Chief Assistant (orporation Counsel

30 North LaSalle Street
Suite 900

Chicago, Illinois 60602
(312) 744-9210
Attorney No. 06184989

DATE: 4 OX, OY

CLoaph OR Prewe

JeSeph M Polick
enior Counsel
Attorney for defendants Finnigan, Rice,
Witzcak and Jaeger
30 North LaSalle Street - Suite 1400
Chicago, Illinois 60602
(312) 742-0029
Attorney No. 06203682

DATE:__ (0 — fo og



under paragraph 12 herein contain the entire agreement between the parties with regard to the

is.action, and shall be binding upon and inure to the benefit of the parties hereto,

jointly and severally, and the heirs, executors, administrators, personal representatives,

successors, and assigns of each.

10. lease and Settlement Agreement is entered into in the State of Illinois and

shall be construed and interpreted in accordance with its laws. Terms contained herein shall not

be construed against a party merely because that party is or was the principal drafter.

Tl. In entering into this Release and Settlement Agreement, plaintiff represents that

he has relied upon the advice of his attorney, who is the attorney of his own choice, and that the

exp. to him by his attorney, and that those terms are fully understood and voluntarily

accepted by plaintiff. Plaintiff also represents and warrants that no other person or entity has or

any interest in the claims or causes of action referred to herein, that he and his attorney
sht and exclusive authority to execute this Release and Settlement Agreement and

ied 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

tary documents and to take all additional actions which are consistent with



a atin vaoaanemeeadN THE UNITED STATES DISTRICT COURT
oa w-EOR THE NORTHERN DISTRICT OF ILLINOIS Qer 5
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v. ) No. 03 C 7888
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PB 0, JEROM! JEROME FIN FINNEGAN, #5167, ) JUDGE GUZMAN
“ARL SUCHOCKI #18391, )
059, ) MAGISTRATE JUDGE LEVIN
E.#11291, )
AK, #9251 ) seen
».O, MARK J #9974 and ) ;
P.O. JAMES ELDRIDGE #2081, ) DOCKETED
individually, ) |
) OCT 9 7 2004 4
_....Defendants. )

. RELEASE AND SETTLEMENT AGREEMENT.

N\



. 3. The parties and their respective attorneys acknowledge that settlement of this

of liability, or of unconstitutional or illegal conduct by or on the part of

any defendant and/or the City of Chicago and/or its future, current or former officers, agents and
employees, and shall not serve as evidence or notice of any wrongdoing by or on the part of any

1. City of Chicago and/or its future, current or former officers, agents and

employees. The parties and their respective attorneys further acknowledge that settlement is

mad oid the uncertainty of the outcome of litigation and the expense in time and money of

for the purpose of judicial economy. Plaintiff and his attorney agree that

they or any firm with which said attorney is affiliated or with which said attorney may later

become affiliated shall not use this settlement as notice of misconduct on the part of any

dor the City of Chicago and/or its future, current or former officers, agents and

employees, or for any other purpose in any other litigation, and that any such use is inconsistent

with e terms of this Release and Settlement Agreement.

‘Tn consideration of this settlement entered pursuant to this Release and Settlement

Agreement, and upon advice of counsel, plaintiff, Thomas Conrad, agrees to dismiss with

prejudi all of his claims against defendants, Jerome Finnigan, Bret Rice, Chris Witzcak, and

* Thomas Conrad, accepts a settlement from the City of Chicago, in the

unt of FIETY THOUSAND AND NO/100 ($50,000.00) DOLLARS, with each side



City of Chicago. “The ettlement check will be made payable to plaintiff, his attorney, and lien

claimants, if any, of which the City has notice.

entered pursuant.to this Release and Settlement Agreement.

“8. ~ Plaintiff, upon advice of counsel, understands and agrees that in consideration of

assigns, all claims he had or has against defendants, Jerome Finnigan, Bret Rice, Chris Witzcak,

~via
and Mark Jaeger, anc

he City of Chicago, and its future, current, or former officers, agents and

employees, including but not limited to all claims he had, has or may have in the future, under

ents

ate, or federal law, arising either directly or indirectly out of the incident which was the

, and that such release and discharge also is applicable to any and all

unnamed and/or unserved defendants.