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It also requires dismissal of the pending action with prejudice upon receipt of the agreed settlement amount and includes a monetary payment obligation from defendants to plaintiff.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/template/","Template",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/template/forms/","Forms",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/template/settlement-agreement-and-release-free-settlment-and-release-agreement-template/283032/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/settlement-agreement-and-release-free-settlment-and-release-agreement-template/283032.png","ImageObject",442,249,{"name":42,"@type":43},"Adam","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-10-23","2026-09-16",true,{"@type":52,"interactionType":53,"userInteractionCount":55},"InteractionCounter",{"@type":54},"ViewAction",6,{"@type":57,"mainEntity":58},"FAQPage",[59,65,69],{"name":60,"@type":61,"acceptedAnswer":62},"What claims does the plaintiff release under this agreement?","Question",{"text":63,"@type":64},"The agreement requires the plaintiff to irrevocably and unconditionally release the released parties from any and all known or unknown claims, charges, demands, and causes of action arising out of the occurrence described in the lawsuit, including personal injury and other alleged damages.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"When will the pending lawsuit be dismissed with prejudice?",{"text":68,"@type":64},"The pending federal lawsuit will be dismissed with prejudice upon receipt of the agreed-upon settlement amount by the plaintiff’s counsel.",{"name":70,"@type":61,"acceptedAnswer":71},"Is the settlement agreement an admission of liability?",{"text":72,"@type":64},"No. The parties agree the settlement and release are a full compromise of a disputed claim and neither the agreement nor the payment is construed as an admission of liability.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},283032,1789588069,{"code":4,"msg":82,"data":83},"success",[84,89,94,99,104,109,113,118,123],{"id":85,"doc_module":22,"doc_module_name":25,"category_name":86,"show_sort_weight":87,"slug":88},11,"Presentations",90,"presentations",{"id":90,"doc_module":22,"doc_module_name":25,"category_name":91,"show_sort_weight":92,"slug":93},12,"Resumes",80,"resumes",{"id":95,"doc_module":22,"doc_module_name":25,"category_name":96,"show_sort_weight":97,"slug":98},14,"Invoices",70,"invoices",{"id":100,"doc_module":22,"doc_module_name":25,"category_name":101,"show_sort_weight":102,"slug":103},15,"Posters",60,"posters",{"id":105,"doc_module":22,"doc_module_name":25,"category_name":106,"show_sort_weight":107,"slug":108},16,"Social Media",50,"social-media",{"id":110,"doc_module":22,"doc_module_name":25,"category_name":29,"show_sort_weight":111,"slug":112},17,40,"forms",{"id":114,"doc_module":22,"doc_module_name":25,"category_name":115,"show_sort_weight":116,"slug":117},18,"Letters",30,"letters",{"id":119,"doc_module":22,"doc_module_name":25,"category_name":120,"show_sort_weight":121,"slug":122},21,"Paper Templates",5,"papers-templates",{"id":124,"doc_module":22,"doc_module_name":25,"category_name":125,"show_sort_weight":4,"slug":126},158,"General","general-158",{"code":4,"msg":82,"data":128},{"doc_id":79,"user_id":129,"nickname":42,"user_avatar":130,"doc_module":22,"category_id":110,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":55,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":136,"language":137,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":138,"faqs":139,"seo_title":140,"seo_description":12,"update_tm":80,"read_time":30},1374404737137,"https://ap-avatar.wpscdn.com/davatar_155a257f0dc6eb9ab79c44ca47cae57d","SETTLEMENT AGREEMENT AND RELEASE  \nTHIS SETTLEMENT AGREEMENT AND RELEASE is hereby entered into as of the 3rd day of September 2015, by and between MALIA “KIM” BENDIS (“PLAINTIFF”) and SERGEANT NICK LIBERIO, DETECTIVE TAMMY SPENCER (F/K/A TAMMY SPENCERHALE), DETECTIVE WOJTEK KOWAL and THE CITY OF NAPERVILLE,(“DEFENDANTS”); collectively referred to as the “PARTIES.”  \nRECITALS  \nWHEREAS, PLAINTIFF has alleged that she sustained damages as a result of the conduct of DEFENDANTS, which is described in the Complaint in the litigation filed in U.S. District Court for the Northern District of Illinois, Malia “Kim” Bendis” v. Sgt. Nick Liberio, Detective Tammy Spencer-Hale, Detective Wojtek Kowal, Officer Juan Rios, and the City of Naperville, Case No. 15-cv-720,(hereinafter called “Plaintiff’s Suit” or “the lawsuit”), and which is hereinafter referred to as the “Occurrence;”  \nWHEREAS, PLAINTIFF has dismissed her claims against Officer Juan Rios with prejudice;  \nWHEREAS, the PARTIES desire to enter into this Settlement Agreement and Release to provide, among other things, for a full and final settlement and discharge of all claims, actions, and controversies of PLAINTIFF for damages, which are, could be, or could have been the object of litigation, on the terms and conditions set forth herein;  \nWHEREAS, it is the express intention of the PARTIES that the purpose of this Agreement is to extinguish all of the claims made by PLAINTIFF so that the PLAINTIFF is forever precluded from presenting a claim or seeking damages against DEFENDANTS, their agents, employers, employees, assigns, officers, directors or representatives, their respective insurance carriers, successors, predecessors, parent or affiliated companies, for personal injury,  \nExhibit A  \nproperty damage, constitutional injury, tort injury or any other damages allegedly incurred by the Plaintiff that in any way arises out ofor from the Occurrence;  \nWHEREAS, it is understood and agreed that this settlement and release is in full compromise of a disputed claim, and that neither this Settlement Agreement and Release, nor the payment pursuant to this Settlement shall be construed as an admission of liability.  \nAGREEMENT  \nNOW, THEREFORE, in consideration of the mutual promises contained in this Settlement Agreement and Release, the parties hereby agree as follows:  \n1. Recitals Incorporated  \nThe foregoing Recitals are incorporated into this Agreement and made a part hereof as though fully set forth herein.  \n2.  PLAINTIFF’S Release  \nIn consideration of the payment of the sum stated herein, PLAINTIFF does hereby irrevocably and unconditionally release, acquit and forever discharge Sergeant Nick Liberio, Detective Tammy Spencer (f/k/a Tammy Spencer-Hale), Detective Wojtek Kowal, Officer Juan Rios, and the City of Naperville, as well as its past, present, and future employees, agents, affiliates, parents, subsidiaries, divisions, servants, representatives, affiliates, predecessors, successors in interest, assigns, insurers, stockholders, officers, directors, underwriters, attorneys or any one of them, separately or jointly, and each member of the Naperville City Council,(hereinafter collectively called the “Released Parties”), from any and all past, present, or future charges, claims, complaints, demands, obligations, actions, promises, agreements, controversies, suits, losses, debts, claims for loss of services, comfort and society, personal injury, rights, damages, costs, expenses (including attorneys’ fees and costs actually incurred), benefits, lost wages and compensations of any nature, or causes of action whatsoever, known or unknown,  \nexpected or unexpected, including without limitation, rights arising out of alleged violations of any state or federal law, which arise from the Occurrence as plead in the Complaint, including all economic and non-economic damages, whether based in constitutional law, tort law, statute, contract or other theory of recovery, which PLAINTIF","cbCaiv8evCKUVIwT","https://ap.wps.com/l/cbCaiv8evCKUVIwT","pdf",182834,9,"English","# Recitals\n# Agreement\n## 1. Recitals Incorporated\n## 2. PLAINTIFF’S Release\n## 3. Dismissal of Pending Lawsuit With Prejudice\n## 4. Monetary Payment","[{\"question\":\"What claims does the plaintiff release under this agreement?\",\"answer\":\"The agreement requires the plaintiff to irrevocably and unconditionally release the released parties from any and all known or unknown claims, charges, demands, and causes of action arising out of the occurrence described in the lawsuit, including personal injury and other alleged damages.\"},{\"question\":\"When will the pending lawsuit be dismissed with prejudice?\",\"answer\":\"The pending federal lawsuit will be dismissed with prejudice upon receipt of the agreed-upon settlement amount by the plaintiff’s counsel.\"},{\"question\":\"Is the settlement agreement an admission of liability?\",\"answer\":\"No. The parties agree the settlement and release are a full compromise of a disputed claim and neither the agreement nor the payment is construed as an admission of liability.\"}]","Settlement Agreement and Release - Free-Settlment-and-Release-Agreement-Template | PDF"]