Common Contracts

1 similar Settlement Agreement contracts

SETTLEMENT AGREEMENT
Settlement Agreement • January 20th, 2022

This Settlement Agreement is made pursuant to Rule 23 of the Federal Rules of Civil Procedure in the above-titled litigation (the “Class Action,” or “Action”). Subject to the approval of the United States District Court for the District of Colorado (the “Court”), this Settlement Agreement is entered into among Plaintiff John Paulson (“Paulson” or “Plaintiff”), on behalf of himself and each of the Class Members (as defined below), and Defendants Two Rivers Water and Farming Company (“Two Rivers”), John R. McKowen (“McKowen”), Wayne Harding (“Harding”) and Timothy Beall (“Beall”) (Two Rivers, McKowen, Harding and Beall are referred to collectively as “Defendants”). Plaintiff and Defendants are referred to here as the “Settling Parties” or “Parties” and each individually as a “Party.” The Parties intend this Settlement Agreement to resolve, discharge, and settle the Released Claims finally and forever according to the terms and conditions set forth below.

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