I-4 - Resolution 2025-010 - Full Release and Settlement Agreement

FULL RELEASE AND SETTLEMENT AGREEMENT This Full Release and Settlement Agreement (“Settlement Agreement”) is entered into this _____ day of January, 2025 (the “Settlement Date”) between the following “Parties” (each a “Party”): • City of Tiffin, Iowa (“Tiffin”); • City of Coralville, Iowa (“Coralville”); • City of North Liberty, Iowa (“North Liberty”); • Clint Rarick (“Clint Rarick”); and • Ruth E. Rarick Trust, including all current and successor trustees to the Ruth E. Rarick Trust (“the Trust”). BACKGROUND A. On December 17, 2019, Tiffin filed a Petition in the Iowa District Court for Johnson County, initiating Case No. CVCV081479 (the “Tiffin Lawsuit”). B. On March 22, 2021, Rarick filed a Petition in the Iowa District Court for Johnson County, initiating Case No. CVCV082399 (the “Rarick Lawsuit”). C. On March 22, 2021, Trust filed a Petition in the Iowa District Court for Johnson County, initiating Case No. CVCV082400 (the “Trust Lawsuit”). D. On May 24, 2021, Coralville filed a Petition in the Iowa District Court for Johnson County, initiating Case No. CVCV082407 (the “Coralville Lawsuit”). All of the foregoing Lawsuits relate to a Tiffin road project which would connect Forevergreen Road in Tiffin to Forevergreen Road in North Liberty (“Tiffin Forevergreen Road Project”). The Parties all recognize that litigation can be costly and time consuming, and wish to compromise and come to settlement of the claims related to the Tiffin Forevergreen Road Project such that the Parties will fully release each other from such claims and all pending Lawsuits will be dismissed with prejudice; and North Liberty is not a party to any Lawsuits but is a Party to this Settlement Agreement as it provides for the construction of Forevergreen Road within its jurisdiction. Terms and Conditions NOW, THEREFORE, the Parties, in consideration of the promises, and undertakings contained in this Settlement Agreement, state as follows: