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qIF3 <br />SETTLEMENT AGREEMENT <br />AND <br />GENERAL RELEASE <br />THIS SETTLEMENT AGREEMENT AND GENERAL RELEASE (the "Agreement ") is <br />made and entered into this _ day of October, 2003 by and between (a) Christine Walters, <br />individually and as legal guardian for her minor son, Derek Walters, (hereinafter, "Christine <br />Walters'), Rob Rutledge and Renee Martinez (hereinafter, together with Christine Walters, <br />"Walters "), (b) Peninsula Habitat for Humanity, Inc. (Habitat "), and (c) the wood <br />City (the "City"). <br />I. <br />FACTUAL RECITALS <br />1. This Agreement is entered into with refere -g-W thing facts: <br />1.1 On or about July 12, 2001, Waltelf filed cemnla>t the U.S. <br />Department of Housing and Urban Development ( " qMong" other things, <br />discrimination in housing and violations of Title3aM the Civil R & Act of 1968, as <br />amended by the Fair Housing Act of 1988, as_AW&l as v i.,. ton 504 of the 1973 <br />Rehabilitation Act and the Americans With Liabilities ) e&f 1990, by both Habitat and the <br />City. Walters' complaints were assigned_HUlTEcase numbed 09 -01- 0791 -8 (Fair Housing Act), <br />09 -01- 0031 -4 (Section 504), and 09 _ (Ta II — ADA). Hereinafter, these HUD cases <br />will be collectively referred to as Ike"HUDDaims'!- — <br />1.2 Hab deny the allegations of the HUD Claims. <br />1.3 Otxor about August 6 Christine Walters, Habitat and the City <br />entered into a Voluntary Compliance A%reement with HUD. <br />--l On or - a mie 23, 2003, HUD issued a Determination of No <br />Reasonable C inconnection with HUD Claim No. 09 -01- 0791 -8, concluding that "Based on <br />the evidence obta investigation, the Department [HUD] has determined that <br />reasonable cause do not exist to believe that a discriminatory housing practice has occurred. <br />Accordingly, -the abouareferenced complaint [09 -01- 0791 -8 (Title VIII)] is hereby dismissed." <br />1.5. It is now the desire and intention of Walters, on the one hand, and Habitat <br />and the C tk,on the other hand, to settle and resolve all disputes, differences and claims which <br />exist or may exist between them as of the date of this Agreement. Pursuant to and in accordance <br />with this desire and in consideration of the mutual promises and releases contained herein, the <br />parties agree as hereinafter set forth. <br />PA \10325411.1 <br />9999050 - 900139 <br />