5f MOS
AT THE REQUESTOF THE PARTIES NAMED BELOW. THE MEDIATOR HAS PREPARED THE FOLLOWING: MEMORANDUM OF SETTLEMENT Case: MILLER V. PORT OF SEATTLE The parties agree to settle this case as follows: Defendant will pay plaintiff $1,250,000.00, a portion of which may be in the form of a structure, solely at plaintiff's option; it is understood that the payment of the settlement (andlor funding of a structure) will be made on or before Jan. 7, 2017 , at the discretion of defendant's insurer; any component of the settlement funds to be structured must be done through EPS Settlements brokers Monique DeanIScott MacGregor and placed with a Chartis-approved life insurance company; payment will not be placed into any 468B trust; the parties agree that $423,000.00 of the total settlement represents damages' for pain and suffering; consummation of settlement subject to Port Commission approval; 2. Plaintiff will sign a release of all claims and a medical indemnity and hold harmless agreement as to any known liens or subrogation claims, including but not limited to the Department of labor & Industries (approval of settlement indicated below); no Medicare payments have been made and none and anticipated (appropriate language in this respect will be included in the settlement documents); 3. The parties will work together to formalize this agreement with appropriate documentation; 4. The pending action will be dismissed with prejudice and without costs; 5. A copy of this memorandum may be introduced into evidence in any proceeding to enforce this settlement (CR 2A). Dated; October 26,2010. PLAINTIF FOR DEFENDANT'S IIVSURER' ,. -.- F APPROVED: FOR DEPT. L&I-
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