General Release
GENERAL RELEASE
KNOW ALL MEN BY THESE PRESENTS:
That I, MARY QUINN, hereinafter referred to as "first party", for and in
consideration of the sum of FIFTY-FIVE THOUSAND DOLLARS
($55,000.00) or other valuable considerations, received from or on behalf of
JAMES L. ROBERTS and MONROE COUNTY, together with its officials,
employees and agents, both past and present, hereinafter referred to as
"second party", the receipt is hereby acknowledged.
('.^!herH?\!f,r used herein the terms "first party" and "second part.y"
shall include singular and plural, heirs, legal representatives and
assigns of individuals and the officials, agents and employees,
successors and assigns of corporations, partnerships or trusts, both
past and present wherever th~ context so admits or requires.)
HEREBY remise, release, acquit, satisfy, and forever discharge the
said second party, of ilnd from all and all manner of action and actions, cause
or causes of action, suits, debts, dues, specialties, covenants, contracts,
controversies, agreements, promises, variances, trespasses, damages,
judgments, executions, claims and demands whatsoever, in law or in equity,
which said first party ever had, now has, or which any personal representative,
successor, heir or assign of said first party, hereafter can, shall or may have,
against said second party, for, upon or by reason of any matter, cause or thing
whatsoever, from the oegmning of the worid to the tidY VI i:hese p..e::,ents;
including but not limited to, any and all claims for damages, costs,
attorneys' fees and equitable relief arising from the termination of Mary
Quinn's employment with Monroe County, together with any and all
claims which were or could have been brought in the lawsuit styled
"Mary Quinn, Plaintiff, vs. James L. Roberts, Defendant," In the United
States District Court, Southern District of Florida, Case No. 96-10134-
CIV-PAINE/Vitunac.
Page 1 of 2 Pages
It is understood and agreed to by the parties that this settlement is a
compromise of a doubtful and disputed claim and that payment is not to be
construed as an admission of liability on the part of the second parties, by
whom liability is expressly denied.
IN WITNESS WHEREOF, I have hereunto set my hand and seal this JtJ
day of Suoe... ,~ 2004.
June.. S6 tft..'1}-
I c::
L...-,.
STATE OF V;~nll<- )
e;-\'I
.~OF~)
I HEREBY CERTIFY that on this day, before me, an officer duly authorized
in the State aforesaid and in the County aforesaid to take acknowledgments,
personally appeared Mary Quinn, me known to be the person described in the
foregoing instrument or who has produced V:. rqi l'l~ .\)y '\Jl?v'~ ki (t'I1'..~ as
identification and who did take an oath and she acknowledged before me that
she executed the same.
WITNESS my hand and official seal in the County and State last
aforesaid this \st day of .:rune. , 2004.
r.
This Instrument Prepared by:
MICHAEL T. BURKE, ESQUIRE
Johnson, Anselmo, Murdoch,
Burke, Piper & McDuff, P.A.
2455 E. Sunrise Blvd., Ste. 1000
Fort Lauderdale, FL 33304
,(954) 463-0100
)._.j(u~_
N TARY PUBLIC STATE OF R..oRIDA- V i(~i()'tL
My Commission Expires: t~ IVl1V-
I~J3,J 00
Page 2 of 2 Pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 96-10134-CIV-PAINE
MARY QUINN,
FILE!> by
.c.
Plaintiff,
vs.
JUL 2 0 ~
JAMES L. ROBERTS, County
Administrator, Monroe County,
individually and in his official
capacity,
CLAlltNct MAPDOX
Cltllll u.s. D151. cr.
1.0. 01' FU. . .......
Defendant.
I
ORDER DISMISSING <;ASE WITH PREJUDICE
This matter is before the court on parties Stipulation for Final Order of Dismissal, filed on
July 9, 2004. The court having reviewed the record, and being otherwise fully advised in the
premises, it is hereby
ORDERED AND ADJUDGED that this action is DISMISSED WITH PREJUDICE. Each
party is to bear its own costs and attorneys' fees. It is further
ORDERED AND ADJUDGED that this case is CLOSED. All motions not otherwise ruled
upon. are DENIED AS MOOT.
DONE AND ORDERED at West Palm Beach, Florida, this ~y of July, 2004.
~c_(7~~
J C. PAINE
UNITED STArES DISTRICT JUDGE
!'
"
cc:
George W. Cornell, Jr., Esq.
Michael T. Burke, Esq.
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