HomeMy WebLinkAboutVFW SETTLEMENT 07/03/2025 SETTLEMENT AGREEMENT AND RELEASE
THIS SETTLEMENT AGREEMENT AND RELEASE is made and entered into
by and between City of Batesville, Arkansas("City") and Harry B. Stokes Post No. 4501,
Veterans of Foreign Wars("VFW").
WITNESSETH:
WHEREAS, on or about May 31, 2024 the City, Arkansas initiated condemnation
proceeding located at 1680 Chaney Drive, Batesville ("property")owned by the VFW.
WHEREAS, that the City paid the VFW $610,000 in the Summer of 2024 for
ownership of said property.
WHEREAS, the VFW contested that this payment was not a fair and just
compensation ("Dispute"), and the condemnation proceeding in Independence County
Circuit Court Case No. 32CV-24-171 is still pending as to total fair and just
compensation due.
WHEREAS, City and VFW desire to settle fully and finally all differences
between them arising from the Dispute.
NOW, THEREFORE, in consideration of the premises and mutual promises
herein contained,IT IS AGREED as follows:
FIRST: City agrees that they pay to VFW an additional $268,750 (the
"Settlement Amount"), due to be paid to VFW upon both parties executing this
agreement. This additional compensation means that the City will have paid the sum
total of$878,750 for the VFW property located at 1680 Chaney Drive.
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SECOND: In exchange for said payment by City, VFW agrees to dismiss its
claim Independence County Circuit Court Case No. 32CV-24-171 and not pursue any
other legal causes of action based on the City's condemnation of said property.
THIRD: The Parties hereby mutually release, acquit and forever discharge
one another from all claims, costs and expenses (including but not limited to attorney's
fees), damages, actions, and causes of action, whether in law or in equity, and whether
known or unknown, suspected or unsuspected, related to or arising out of the subject
matter of the Dispute.
FOURTH: This Settlement Agreement and Release shall not in any way be
construed as an admission by Parties of any acts of wrongdoing whatsoever with respect
to the Dispute and neither the existence of this Agreement nor the terms herein contained
shall be used as an admission or evidence of wrongdoing by any party.
FIFTH: Parties acknowledge that they have been represented in
negotiations for and preparation of this Settlement Agreement and Release by counsel of
their own choosing, and each of them or their authorized representative has read this
Settlement Agreement and Release and has had its contents fully explained to them by
counsel of their own choosing and is fully aware of its contents and its legal effect.
SIXTH: This Settlement Agreement and Release sets forth the full and final
agreement between the parties hereto and neither party is relying on any statement,
representation or promise made by any party that is not specifically included herein. This
Agreement may only be modified by a writing executed by both parties hereto.
SEVENTH: This Settlement Agreement and Release may be executed in any
number of counterparts by original or electronic signature, and each such counterpart
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shall be considered an original,but all of which together shall constitute one and the same
agreement and shall be fully effective against all persons executing it.
THIS SETTLEMENT AGREEMENT AND RELEASE
INCLUDES A RELEASE OF CLAIMS.
Executed this of t k 2025.
ANIEL R. HANEY
ATFORNEY for Harry B. Stokes Post No. 4501
Veterans of Foreign Wars of the United States, Inc.
467k o a
BARBARA HENSON
Authorized Agent for the Harry B. Stokes Post No.
4501 Veterans of Foreign Wars of the United States, Inc.
RICK EL
Mayor of the City of Batesville, Arkansas
jAmey
HY EITZ'for the C atesville,Arkansas
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