This Settlement Agreement and Release (Agreement) is entered into the day of June

16, 2015, between Ricik Jones (the victims mother) and the Metro City Council, who

is responsible for managing the tap water in the Metro City.

BACKGROUND

1. On September 16,1996, 24-year-old Samuel Jones died of pindiatiosis in

connection with AIDS. He had AIDS for several months, but his health worsened

after he drank water containing Pindia, a parasite found in the Metro City tap

water. The numbers of this parasite had increased due to the poor condition of the

citys pipes. Metro city is located in the state of New Governland.

2. The Metro City Council became aware of Pindia in October of 1993, while testing

for difficult to detect protozoa and bacteria in the citys water system. The city

received special funding from the federal government, a one payment of

$200,000, for this testing as part of national survey of the quality of drinking

water. After discovering the presence of Pindia, Metro City began testing the citys

water system twice a year. The population of the Pindia rose as the Metro City

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water pipes steadily deteriorated. In order to solve the problem, the city takes the

following measures:

a. The City Council sent notice to residents and published the warning in a

locally-read newspaper. And there were several posters about this in the

House of Friends, a witness could testify that people in the clinic were

aware of such a parasite crisis in the city.

b. The city used the emergency funds issued by the FWSA (Federal Water Safety

Advisory) to replace the most deteriorated section of the water system pipes.

As a result, by August 1996, the level of Pindia had leveled off at 400 per

gallon, which is a level safe for general public consumption. However, the city

did not have the 100 million dollars necessary to replace the entire water pipe

system.

c. On september1, 1996, the city began to flush the water system with chlorine, a

chemical that kills Pindia. On September 15, the levels of Pindia had dropped

to 278 Pindia per gallon, a level below the threshold level of minimal health

risk.

d. The City Council has monitored the water system for any increase in the

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 parasite numbers on a regular basis, every six months, which was reviewed

and checked by the Biology Department of Metro City Research Institute.

3. Sam took the therapy in the House of Friends, an AIDS clinic located in Metro

City at Thirteen McLean Avenue. He did not get any financial support from his

rich parents and rarely contacted with them and his friends. There is a possibility

that Sam did not see the posters in the clinic.

4. The doctor could prove that Sams death is directly caused by the parasites in the

tap water of Metro City. And Sam could have lived longer even with AIDS

infection.

DEFINITIONS AND STIPULATIONS

1. Pindia is a kind of water parasite that could causes upset stomachs, nausea and

diarrhea. Especially, its fatal to peoples health when he or she has vulnerable

immune systems, such as systems with AIDS.

2. The notice and news could be found in the August 1-7,1996 issue of Metro City

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 Times, Community Notices section.

3. The scientific data are derived from the Metro City water quality advisory, August

1,1996 and Graph of Pindia population in Metro City water system, submitted by

the Metro City Office of Public Utilities.

TERMS AND CONDITIONS

1. All the following agreements are based on the facts that we both parties accept.

The parties reserve the right to dispute any other legal or factual conclusions

based on these items and to make objections to these items based on other

evidentiary issues.

2. The Metro City agrees to pay all victims doctor and hospital bills, funeral costs

and compensation for pain and suffering for Sam. Considering the victim self-

condition with AIDS and his relevant longevity, the efforts by the Council to

manage the water and the relationship between the victim and his parents, we

agree to cut off half of the rest damages the plaintiff asks for. And we agree on a

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 total of $1,580,000 for damages and here is the calculation:

a. Loss of Consortium. Both parties agree that Ricik Jones has a life expectation

for 10 years according to the scientific study. Therefore, the metro city is

supposed to pay $ 20,000 a year for 10 years, which means $ 200,000 for loss

of consortium.

b. Hospital Bills. Both parties agree on $ 15,000 doctor and hospital bills for

final stay in hospital.

c. Funeral Costs. Both parties agree on $ 5,000 for funeral costs.

d. Damage for Pain and Suffering of Parents. Both parties agree on $ 500,000

for pain and suffering of parents.

e. Damage for Pain and Suffering of Sam. Both parties agree on $ 60,000 for

pain and suffering of Sam.

f. Punitive Damage. Both parties agree on $ 500,000 for punitive damages for

Sams death.

g. Lost Wages. Both parties agree on $ 30,000 a year for 10 years, which means

$ 300,000 for lost wages to estate.

3. Mutual Non-admission. Both parties agree that nothing in this Agreement shall

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 be construed as an admission by either of them of any wrongdoing or violation of

any applicable law.

4. Non-disparagement. Metro City agrees that she will not make any disparaging

comments or statements concerns Ricki Jones and her family.

GENERAL PROVISIONS
1. Choice of Law. This settlement agreement shall be governed and construed under

the laws of the state of New Goverland.

2. Choice of Forum. The parties agreed to the exclusive jurisdiction of the courts

located in the state of New Goverland with respects to all claims and disputes

arising under or relating to this agreement.

3. Modification. No modification of the terms of this agreement will be valid unless

the written consent of both the parties.

4. Severability. Should any portion of this agreement be held illegal or

unenforceable by a court of jurisdiction, the validity of the remainder of this

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 agreement shall not be affected.

5. Merger/Integration. This agreement supersedes and replaces all prior and

contemporaneous oral or written agreements, negotiations, promises among the

parties.

6. No-admission of Liability. The parties understand and agree that this settlement

agreement is entered to resolve the disputes between the parties and can not be

construed to be an admission of liability of any of the parties.

7. Notice. All notices required under the terms of this Agreement shall be made in

writing and shall be verified by the both parties.

The parties agree to the terms of this Agreement, on the first date referenced above.

Signature by both parties: