HomeMy WebLinkAboutCAG2023-134 - Original - Vladimir Pavlovich - 21-2-13630-0 KNT Settlement - 01/24/2023Ap
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rev. 20210513
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CR2A MEMORANDUM OF SETTLEMENT
BETWEEN:_Pavlovich ("Plaintiff') and the City of Kent and Baughman ("Defendant")
Cause No. No. 21-2-13630-0 KNT
The undersigned agree the above matter and court actions, if commenced has been settled on
January 23, 2023 following mediation with Paris Kallas at JDR which was held on January 10,
2023, on the following terms:
The Citv of Kent will pay $ 625.000.00 to Plaintiff. The check should be made payable as
follows:
G_LP Attornevs, P.S., Inc. in trust for VLADIMIR PAVLOVICH, as Personal
Representative of the Estate of Sergev Pavlovich
Plaintiff counsel's tax ID No. is: Tax ID 91-1353432.
Other agreed terms and conditions:
1. Plaintiff agrees to release and forever discharge all claims against the Defendant arising
out of the subject lawsuit, and to satisfy all outstanding bills, subrogation claims, or liens
and will execute a hold harmless agreement with respect thereto;
2. The parties will work together to formalize this agreement with appropriate
documentation;
3. Plaintiff agrees to dismiss the lawsuit with prejudice after the receipt of the settlement
funds. Defendant shall prepare a Stipulation and Order of Dismissal;
4. A copy of this agreement may be introduced into evidence in any proceeding to enforce
this settlement pursuant to CR2A; and
5. The Defendant will send the check to Claimant's counsel within 45 days of receipt of the
release. In the unlikely event that is not possible, Defendant will notify the Claimant no
later than the 45th day after receipt of the release.
Other than as stated above there are no additional representations or agreements of the parties.
Brian Aug enthaler for the City of Kent
And Patrick Baughman
Signature
Seattle. WA
Date: I ' 2� • 2013
Cydney Campbell Webster for Plaintiff
Signature
Seattle, WA
Date: 1/23/2023