'SETTLEMENT AGREEMENT AND RELEASE

- -.Cfoi:n~rly RB.), an fn:fant.by J{is G.UI'.dian

PLAINTIFF:

:rfflem, Barbara Klem

State of New Jersey Division bfYouth and Family Setvices (''DYF.S."),
State ofNW Jersey Department of Chlldren and Families, and State t).f

DEFENDANTS,

New Jersey employees; Diane Smith, M. Olmo, Curtis Carter;

Lisa Marie Finnegan, fyf. Baena, B. Blakely; Joe Gorman1 and
H. Torres-Mejias

Liberty A.$-sigpm.en.t Corporation

ASSIGNEE:

l his Se\tlei:nent Agreement and Release ("~ett,letnent Agreemebt'i) is inade and nteted into

this

1J i:liy of

l':<AAZA!:'-.~o 16, b.y anq between Plamtiff and Defendants.

RECTI'ALS

or

I.
On about October 5, ZO 11, the Plaintiff coririnenced. -an Action against :the
Defendant in the Supetior Court of the State of New Jersey, Essex County (Dtick.et. No, BSX-L8102-11) bY th.e.filing of~ stQ:DJD:ons. Ej.Ild verified cq:rp.plaint (tbe "Gomp-laint~J '_fhe Action arose
out of the aileg_e<l negligent acts or omissions.o f th.e Defendants, and the Plaintiff sought to recover
monetary damages which were alleged Jo be the pi:.oximate result of incidents occunuig betw~n
late2ooi through PP. or &bout Match 22, 2022.. that reS'llited in physical injuries. to Phiirttiff.
The parties -desire to enter ip.to tb.i.s Settl~ment Agreement in order to provide for
certain payments in full settlement and discharge of ,all claims which are.ilie subject-of or might
have been the subject of the Complaint, upon the terms and conditions set fortJ:i. herein.

.II, .

AGREEMENT
the partie_s hereto hereby agree ,as folloy.,s:
A.

Reiease and Discharg.e

Xn qon.sidet~:l:.ton of th~ peym.ertts called for herein, the.Plaiptiff (sometimes refe1Ted to het:ein
as "Relea$oi:'') hereby compietely r~le.ases ~cl .forever discharges the State of New Jersey,
Defendants and said Parties' past, present and future officers~ directors, s.tockholders, attorneys,
insurers, a.gents, servants, reptesentati\re.$, emplo:ye.es, s1;1.b.s.iciiaries, affiliates, partners, p:reilecess.ors
and ,sticcessors in interest, $.d ~ssigns &rt.d all othet p.ersq:p.s, .PP.liS or corporations with v.1hom ~ny
of the foM,rbave-been, atehOW or-may )iereaftet be 1.ffiii,at~d .(s0.metimes referted to ~er~in as
i1 Rele!lsee.s11 or 11R~leased Parties'"); of
from any and all past, present or future claims, demands,,.
obligations,. actions,. causes of action, wrongful death claims, rights, dam.ages,
. . . costs., io.sse-s of

and

'

services, expenses and compensation of any nature whatsoever, whether based on a ioti, contract or
other theory of recovei-y, and whether for compensatory or punitive damages, which the Plaintiff
11QW ha:s, 01 which may hereafter accrue o:t otherwise be acquired, 0J1account of, ot may in any way
gt9w out of, or which are the subject of the Complah1t (and all related pleadings) ificluding, Without
limitation, any and all lmown or unknown claims for bodily a:rtd petSonal i11Jnries to PlruI1tiff, or any
fut11re wrongfu1 death claim of Plaintiffs representatives; which have resulted or may result from
the alleged acts or omissions of:the Defendants. This release shall be a fully binding and complete
s'ettlement between the Plaintiff and the Defendants, their assigns and successors, save only the
executory provisions of this Settlement Agreement
B.

Payments

(i) In consideration of the release set forth above, the State of New Jetsey, on behalf of
Defendants, hereby agrees to pay the Plaintiff the following sums in the following manner all in
accordance with and pmsuant to the Order of the Hon. Dennis F. Carey1 III, dated March 11, 2016.

1. An 11p-frot1t payn'lent of $782,985.67.

2. Future periodic payments as set fo1ih in Exhibit f'Au atti;tched hereto lllld made part of this
agreement. The cost to the State of New Jersey of the future periodic payments portion of this
settlement is Four I-Iundted Sixty 81.wen Thousand Fourteen and 33/100 Dollars ($467,0i4.33),
o.isclosure of which has been required as a condition of settlement No part of the sum being paid by
the State of New Jetsey to provide future periodic payments as set forth in this Settlement
Agreeme11t may be paid directly to Plaintiff, inasmuch as the paiiies negotiated for and the court has
determined that a structured settlement is in the best interest of the infant Plaintiff and that .said
pedodic payments constitute damages on account bf physical injury or physical sickness in a case
involving physical injury ot pl:tysical sidmess within the meaning of 104(a)(2) and 130(c) of the
Internal Revenue Code of 1986, as amended.

(ii) All sums set forth herein eonstitute damages on account of physical injudes or physical
sickness, within the meaiung of 104 (a.)(2) and 130 {c) [as regards the futme pedodic payments]
of the foternal Revenue Code of 1986, as amended.

(iii) It is understood and agreed that the State of New Jersey shall pay a total of $782,985.67

111 11up-front" payments (as outlined in para. B (i) (1) above). The Defendants have notice of a
Medicaid lien in the aiuount of $298,009 .49 wliic;il1 shall be satisfied from the up-front cash potiion
of the settlement. In the event of the existence qf any other otttstanding liens atismg from the
incident des<:ribed in Recital I, it is understood and agreed that the PJaintiff shall be responsible to
resolve and/or satisfy any and all such liens and the Plaintiff shall indemnify and hold the
Defendants hannless from any and al] such claims made by liehholders, whether such claims have
been made, or are iri the fi.1ture made.
Plaiittiff will fully resolve and!or satisfy any ai1d all valid liens from the proceeds of the
settlement Plaintiff hereby discharges and agrees to indemnify and save hannless the Defendants
from any liens asserted by any health tare cai'tie1:-; health car.e provider, hospital, insurer or attor11ey

for me.die~ 'tpehSes, hospital ex.petises, lost wages payments, attorneys liens, s11bto:g:ati9n claims or

l~ens Qt any eb,ild supp.ott, workers' con1pen$ati9n, Medicare or Medi,caid ll.e:ns to the e;&.tent.

required to be .p~id in accordarrce witlT fhe law whi9h is a result of the ~ceurrence Pr. against Plaintiff
whether ot not.it pertains to this occurrence; Plaintiff hereby certifies and l'epresents to the
Rele.asees that Pli:1.in'til:f has fully dlsclosed the name? address, telephone b.urp,ber, policy nuniber1- and
"Qlm, p._1Jihp.~'l'., a,nd docket.-edjudgment num'ber for child support, i.fany, as w~ll as ampnt claim.ed,
a:s a lien, 1:>y apy hea(th care c.arrier, health care pro.vider~ workers? compens~tion carrier,
subrogation insurance canier, or attorney as a result of tb.fs occunence against PJ.aintiff whether
or riot it pertains to this occttr'J:ence.

or

'The Plajp:tf. forth.er agre(\ls, represenis, and certifies tb,at Plaintiff will pay the fully agreed
upon amount of;an,y en asseited as outlined above directly out ofthe proceeds of this settlement.
The Plaintiff hereby further agrees to indemnify and hold harmless the Releasees from any future
lien which.has not been previously made known to the,_parties herein.

P1aintfff re.presents and w~a.ntS. that a child supp.oi}j:i:glgm.ent.se;'lto.h has b~e.11 eonduoted aS,
req~ire~ 3 b and that sa}cl.seei:.rch has found no child s.upp.ort judgments outstanding
agamst . . . . . . . .
(iv) It is unqetstop.q :l[l:119 agreeq. that th~ State of New hrs.ey shajl issue its up-front payment
as des.cribed in para. B (i) (1). and shall fund the. structured s.ettlement annuity by May Q.,, 2016~
(v). The term II guaranteedII as lt is used in Exhibit "A" hereto shall be consfme.d to mean
"payments that will be matfo whether the PiaintifflP-ayee is alive or not at th:e time-the payment is
due..-' S4ol,l!d. the Plaintiff/Payee expire prior to re~eipt o.fall pa.ymepts described as ''guarantee<l11,
the remainder of the "guaranteed'' paypients shall be payable as set forth in Section'F below entided
"Plaintiff's Benefi.ciary"i.
C.

Plaintiff's Rlghts to Payments.

The future periodi'c paymentS, des~ribed mpara. ~ (i) (2) above cannot be accelerated,
defened, increased or decreased by the Plaintiff or any Payee and no part of the payments called for
herein or any specific assets of the State bf New Jersey are to he subject to execution of aiiy legal
process for any obligation of the Pla:intiff or ;my Payee in arty ri1anner, not shall'the Plaintiff ot any
Payee have the power to s.ell o.t m.cgtg~_g~ ot en.cumber sru;ne,. or any pru:'t the:i:~ot not anticipate th
sam.e, or attY part to.ereof, by assignment or :o'therwise unless such sal~, assignment.,. pkdg~,
hyp.othecatiori or other transfer or encumbrance has been ap,proved :in advance in a ''Qualified
Order'' as defined 5891(h)(2) of the futeina1 Revenue Code and otherwise comphes with
applicable state law, including without litn:itation any applicable state structured settlement
protection statute. Any attempt by Plaintiff ot any Payee-to so assign, lUlticipate, pledge or
encur;ri.per lUlY annuity paym.ents without complying with the requirements Internal R~venue
Code 5891(q)(2) and any applicable state law shall be null and void and shall not.affect the
Plaintiffs ot any Payee;,s rights to receive annuity payments. Transfer Qfthe periodic payments is
thu$ prq);ribited by th(rtenns of 1:bis structured settlement and may otherwise be prohibited ot
restr1cted underapplioal>le law.

of

.3

Right to Execute an Asslgntnent of Liability

It is undetst9oq an:cl agteed by and betweet1. the partiei:; hereto that th~ State of New Jersey
sl;ia:11 assign its duties and bbligations to mak:e the future periodic payments as s'et forth iI1 Exhib,it
"Au to Liberty Assignment Corporation ("Assignee") within the meaning of 130(c) of the Internal
Revenue Code of 1986, as amended. Such assignment is hereby accepted by Plaintiff without right
of rejection and ih full discharge and rel~se of the duties and obligations of the State of New Jersey
to make the future periodic payments set forth on Exhibit ''A". The Assignetf s obligation for
payment of the periodic payments is no greater than the obligation ofth~ person or entitymiginaJly
liable (whether by suit or agreement) for payment and from whom the obligation was :assigned. The
pa1iies hereto expressly understand and a:gtee that upon the assigrnncnt of its duties and obligations
to make such future periodic payments being made by the State of New Jersey to Assignee pursuant
to this agreement, all of the tluties ::i,,nd responsi'l?iltties otherwise imposed upon the State of New
Jersey by this agreement with respect to such future payments shall instead be bindirtg 130Jely upon
Assignee. Liberty Mutual Insurance Company will provide a Certificate ,of Guarantee that allows for
Liberty M'lJtq,al Jnsurance Company to assun1e the responsibility tb 1:nake any and all payme11ts under the
annuity contract in the event that Liberty Life Assurance Company of Boston were unable to Itialce said
payments. Liberty Life Assurance Company of Boston wiII provide a Certificate of Guarantee as
evidence ofits financial guarantee over the perfodic payment obligatfon of Liberty Assignrnent
Corporation.

The Plaintiff :further and fully recognizes and agrees that the Assignee shall be Phfoitiffs
sole obligor with respect to the obligations assigned, m.id that all other releases that pertain to the
liability-of the State of New Jersey and all Releasees with respect to the future periodic payments
shall thereupon become final, irrevocable a:nd absolute.
E.

Stipulation Regarding Settlement Obligations And Novation

Ttis understood that the State of New Jersey is not a guarantor or insurer with respect to t:lie
aforementioned annuity. The purpose of this stipulation is to make clear that the obligations and
resppnsibilities of the St,ate .of New Jersey are satisfied upon iss'tlartce cif the aforementioned
settlement monies and the execution of the qualified assignment.
Inrecognition of the obligation of the State of New Jersey specified above and the release by
Plaiiitiff, the parties further agtee as follows:

It is agreed that the State ofNew Jersey will assign, the obligation to ml:lke the specified
periodic payments to the Assignee. The obligation of the State oflfew Jersey to make periodic
payments shall, by this novation, become the sole and exclusive duty of the Assignee, and the tenns
mid co:nditions of payments shall remain unchanged :m lieu offue substitution of the Assignee for
the <>bligatkms of the State ofNew Jyrsey.
Execution of the Qualified Assignment and funding of the annuity will absolutely and
completely discharge the State of New Jersey from any further future periodic payment obligation.
If either the Assignee or the issuer of the annuity conttact :purchased by Assignee to malce the
payment obligation specified above fail to make payments or become insolvent or bankrupt,
Plaintiff or Plaintiffs heirs or representatives' sole :remedy to enforce the payment obligatio11s
4

assigned shall be against Assignee, the guai:antots, Uherty Mtimal Insurance Company and Liberty
Life.Assurance Company of Bost.on, an:c1iot qther responsible party other than tbe State .ofNew
1.~rsey. the State ofNew jersey will l:).ave ab$6lutely no fuu;rre pi;:riodrc payment obligations tb
Plaintjf.f or any Payee under those circumstances.
F.

Riglit to Purchase an Annuity

The State of New Jetsey-i!! Ass.1gue~ may, fur its own c:tmvenience, fqnd it$ obligation to
make the,f1,1fore periodic payments under the t~m:i.s 9f this agreement a~ set forfh ip. .Exhibit "A11
throu,g11 the purchase.o f an annuity from Liberty Life Assurance Company of Boston e'Annuity
Issuer"). Neither Plaintiffnot anyone acting on Plaintiff's behalf: shall have any right of or
incidence o:f ownership w.hatsoever fo the annuity policy; shall hirve any right to :acpeierate t>.t d~fer
pay:tnents due from the Assignee~ shwI hl:1-Ve any right to increase or deqr.e~e ai:).y pay.:p::i;ents :~ki:e
frqJ;n tbe As~ignee; shall have any olli,er right 9f dominion or control ofor over lhe annuity policy,
which shall be owned exclusively qy the. Assignee.. The Assignee 1:i:J.ay have Liberty Life Assurance
Company of Boston mail payments directly to the Payee/Payment Recipient,

G,

.I

Plaintiff's Beneficiaty

In the event ofthe death of

all iguatanteed non-life, c.ontingent. payments
specified in Exhibit "N' to be made by the. Assign .e -.111'S])t to the provisions ohhis agreement
thar have 1;iot been paJ.4 as of the. date ocl!"a:th, si::tal..l be c.oni:hluted to present
value .and paid in a single Jump sum to ~
.K. Irrev9ciible (d)(4)(a) Special Needs Trust as s-et
fortb below;

If Annuitant,- - dies b~fore May 41 2056, then 10.0%:ofthe Commuted

Value of the rem~ing unpaid guaranteed payments will be paid to the Bene:fidary in a lump SQm.
The Commuted Value will be 93 percent of Liberty Life Assurance Company of Boston's
cost for an annuity providing the remaining unpaid guaranteed. payments. Llberty Life Assurance
Company of Boston wiii compute their .cost1 as of the Date of Commutation, -using their annuity
tat!;ls fol,' the same or similar contra<~ts in effect on the Annuitant's date of death. If such annuity
rates are not available, the Commuted Value sMII be the present value, as oftb.e D,flte of
Commutation, of the remaining unpaid guaranteed payments calculated using the following interest
rate: The annual effective yieW of the most recently ptiblished Moody's Long..:Term Corp.orate Bond
Yield Average phis 0.10% as of the Annuitap.t;s date 9f death. hi ihe ev~tthattheM.oody~s Lp-ngJ'i',.pn Co;i:pct1;~te Bond Yield Averag~ is ttQ longer avatfaqle, then a similar reference rate
be
u,sed. The Date of Commutation will be 0)1 or before the 15th calendar day afte:i; Liberty Life
Assurance Company of Boston's receipt and acceptance of due proof of death.

will

P~yee/ Payment Recipient, or a duly authodzed teptese:ittative of1he Payee/Payi:nent

R~cipie,:i.t, shall be responsible for maintaining accurate address ati.d PJ.ortality information with the
Assignee.

H.

.Attorney's Fees

Each party heret9 sb,all bea:r all attorney's fees @d costs arising fronl the actio.p.s ofits bW'.11
cmmsel i!l connection with the Complaint; this Settlement Agreement, the Qualified Assignment,
and all other matters and documents referred to herein including, but not limited to, the preparation
and filing of all documents necessary, customary and/or appropriate to accomplish the disnii~sal of
the Complaint with preJqdice and without costs, and aU related matters.

1.

Delivery of Dismissal with Prejudice

Concunently with the execuJion of this Settlement Agree1ne11.t, counsel for the Plaintiff shall
deliver to counsel for the Defendants all appropriate documents necessary to accoinplish the
dismissal and discontinuance with prejudice of the civil action described in Recital ''I" above which
shall be held in escrow; The Plaintiff has authorized the Plaintiffs attorneys to execute these
docl.iments on Plaintiff's behalfahd hereby authorizes counsel fot the Defendants to file said
documents with the Court and enter safd disniissl:t1 as a matter ofrecotd once. all cash amounts due
and funding for the annuity have been paid and cleared.

J.

Reservation of Rights

Notwithstanding ,anything to the contrary found elsewhete in this agreement, it is understood

and agreed that the Plaintiff specifically reserves Plaintiff's rights to Pt!tSue an action fot dan,1ages
resultant from the occurrence sued upon herein against Harvest of Hope. Nothing contained in this
agreement shall be construed as a release of Plaintiff's claims against Harvest of Hope.
K,

Supplementary Doc4111ents

All parties to this Settlement Agreement and Release agree to execute any and all
supplementary documents and to take all actions required to implement and to g~ve full force and
effect to the terms and intent ofthis agreement.
L.

General Release

The Plaintiff hereby acknowledges and agrees that the release. set forth in Paragraph A
hereof is a ge1wral release a.nd. Plaintiff further expressly waives and assumes the risk of any and all
cl?UIDS for damages which exi.st as of this (:late but o:fwhich the Plaintiff does not know or Sllspect to
exist~ whether thro1Jgh ignorance, oversight, error, negligence, or otherwise, and which; if known,
would materially affect Plaintiffs decision to enter into this Settlement Agreement. The Plaintiff
further agrees that Plaintiff has accepted payment of the sums specified herein as a complete
compromise of matters involving disputed issues oflaw and fact, and Plaintiff assumes the risk that
the facts or law may be otherwise than Plaintiff believes.
M.

Warranty of Capacity to Execute Agreement

The Plaintiff :represents and warrants that no other person or entity has or has had any
interest in the claims, demands, obligi;ttions., or causes of actiortreforr~d to. in this Settlement

Agreement except as otherwise setforth herein and that Plaintiff has the sole right an:d exclusive
authority to execute this 8ettien1ent Agreement and receive the sum or sums specified in it; an<l that
Flaintiffhas not sold, assigned, transferred, conveyed, or otherwise disposed of any of the claims,
demands; obligations, or caqses ofactio11 tefe.rred to in this Settlement Agreement.
N.

Discharge of Obligation

The qblig;ition assumed by the Assignee to make each Periodic Payment shall be fully
discharged upon the mailing ofa \lalid check or electtonic funds transfer in the amount of such
paymenton or before the due date to the last address or account on record for fuy Payee ot
Beneficiary with the Annuity Issuer. If the Payee or Beneficiary notifies the Assignee that any
check or electronic funds transfer was not received, the Assignee shall direct the Annuity Issuer to
initi.:tte a stop payment action and, upon confitma.tion that such check was not previously negotiated
or electronic funds transfer deposited, shall have the A11nuity Issuer process a replacement payment.

0.

Payee Representative

tf at any t:ime any Payee is for at1Y reason Iegl:l.11y incapable ofacting on such Payee's own
behalf, all notices, designations, or instruments required or pennitted to be exec11ted by ot delivered
to such Payee and all payments required to be made to such Payee shall be executed at1d delivered
to orby, and paid to, any legal guardian, conservator, custodian, or trustee (any of the foregoing
being hereinafter referred to as a "Representative") appointed to act or such Payee or with respect
to such Payee's property. All payments made to any Representative shall be held and applied by
such Representative solely for the benefit of the Payee for whom such representative acts.
P,

Entire Agreement and Successors in Interest

This Settlement Agreement contains the entire agreement between-the Plaintiff and the
Defendants with regard to the matters set forth herein and shall be binding upo11 and inure to the
benefit of the executors, administrators, personal representatives, heirs, successors, and assigns of
each.

Q.

Representation of Comprehension of Document

In entering into this Settlement Agreement; fue Plaintiff represents that Plaintiff has read
the terms ortm,s Settlement Agreement and that those terms atefully understood and voluntarily
accepted by Plaintiff. In entering into this Settlement Agreement, Plaintiff has retained and
consulted with Plaintiff's own independent attorneys selected by Plaintiff of Plaintiffs own free will,
and has fully and freely consulted with them on matters relating to this settlement and its terms at1d
conditions. Plaintiff acknowledges that this Settlement Agreement has been negotiated by the
respective Parties through co.1,msel. The Parties to this Se.ttlement Agreement contemplate and
intind that all payme11t1;, set forth in Section B above constitute damages rec.eived on account of
personal physical injuries or physical sickness;; arising ITO!Jl the occurrence, Within the :meaning of
104 (a)(2) of the Internal Revenue Code of 1986, as an;11.3nded. Plaintiff acknowledges receipt of
the following disclosures relating to the Periodic Payments: the annuity preniiurn payable to the
Annuity Issuer as defined i:o Section B (i) (2) for the aforementioned pettodic payments is

$467,014.3.3; no costs may be deducted from.any of the Periodic Payments; any transfer of the
Periodic Payments is prohibited by the tetms ofthe structured settlement and may otherwise he
prohibited qr restricted under applicable law; Plaint;if:f has been advised to obtain or has o.btained
independent professional advice relating to the legal, tax, financial or other (favoraple or adverse)
consequences of any kind arising out.of the settlement; the Defendants or Defendants' legal
representi;1.t1ves may not refer any advisor, attomey or firtn for such purpose: and the Plaintiff is not
relying on the advi6e of the Defendants or anyone associated with them, including their at101neys
for such purpoi;;e. Accordingly, the Plaintiff hereby relef):ses and holds harmless the Defendants and
any and all counsel for the Defendants from ap_y claim, cfj.use of action, or other rights of any kind
which the Plaintiff may assert because of the legal, tax or other consequences of this Settlement
A.gteement :Plaintiff represents and wanants that Plaintiff has read and discussed this Settlement
Agreement and Release fully \vith Plaintiffs attorneys and has had the opportunity to obtain the
consult ofoiher attorneys and tax advisors of Plaintiff's choice and fully U11derstands its terms and
conditions, and voluntarily accepts them as Plain.tiffs own free and voluntary act.

R.

Gpvet:ning Law

1bis Settlement Agreement shall be construed and interpreted in accordance with laws of the
State ofNew Jersey.

S.

Multiple Counterparts

This Agreement may be executed by the parties in multiple counterparts (although not
required) and all of such counterparts so executed shall collectively constitute this one Agreement
and shall be deemed to establish this one Settlement Agn'iement. For purposes of executing this
Settlement Agreement, a document signed and transmitted by facsimile machine or scan and email
is to be treated as an original document. No Party may rajse the use of a facsimile machine or scan
or the fact that any signature was tram,mitted through the use of a facsimile or scan and email as a
defense to the enforcement of this Settlement Agreement.
T,

Captions and Pi:ira.graph Headings; Constwction

Captions and Paragrl:!,ph headings used in thi;s Settlement Agreement are for convenience
only and are not a part of this Settlement Agreement and shall not be used in construing it. The
terms, conditions and other provisions of this Settlement Agreement have been negotiated between
the parties, with each party having had the benefit ofits own legal counsel. The constniction and
interpretation of any clause or provision of this Settlement Agreement shall be const;rued without
regard to the identity of the party that prepared this Settlement Agreemep,t, and no presumption shall
arise as a result that this Settlement Agreement was prepared by one party or the other.
U,

Severability

In the event that any one or more of the provisions of this Settlement Agreement shall be

held. invalid, ii1egal or unenforceable in .any respect by a court of competent jurisdiction, the
vaii:drty, legality and enforceability of the remaining provisions of this Setilement Agreement shall
ndt in any way be affected or im.plllred thereby.
8

V. Bffectivehess
This Settlement Agree!Jl~nt shall be executed immediat~ly, but shall qul,y b9on1e effective
after the Court has approve.ct the settlement. By his or her ~ignature below, e~cli p~rt:y I'.~p.tents
ahQ warrants that he or .she has the full authority to bind the person,.persons or e1itity'fQr whoni
eX.ecution of this agr~eme:ot is being m~dt,

~tVJ1iho16.

Executedthis.\ Y~~yof

State of New Je.tsey

-~4~

-Bar6ara Kie.in, as Guardian

Authotized Representative

ad Litemof

Printed Name
Title
Date

AC KN OWLED GEM E'NT:

STATE OF NEW JERSEY

)
)

COUNTY-OF r::.:s:JC;<

ss.:

On tqe I I 1i.. day of n,1,(.::..11

2016 bef'ore me., 'the undersigned, personally appeared Barbara

Klem, personally known me or proved to me on the J.jasjs ofsatj.sfuctory e.vicfonce to be the
individual whose-name is subscrib~ to the within -SETTLEMENT AGREEMENT i:Qld RELEASE,
and acknowledged to me that she executed the same in her capacity, and that by b,er,signa,tute pn.fhe
SETTLEMENT AGREEMENT and RELEASE; the individual, or the person upon behalf of whl;>lll
the individual ~te<i., executed the SETTLEMENT AGREEMENT AND RELEASE.

to

.A- :~
Notary

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