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-