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SETTLEMENT AGREEMENT AND
COMPLETE RELEASE OF ALL CLAIMS
This Settlement Agreement and Complete Release of All Claims (hereinafter
"Agreement") is entered into by and between Errol Varnadore, hereinafter the "Claimant," and
the Board of County Commissioners Grant County, Washington (hereinafter the "County"), and
is intended to settle and resolve all claims and allegations asserted by Claimant against Grant
County Clerk's Office, in the State v. Varnadore matter under Grant County cause number o0-1-
00050-5.
1. In exchange for and/or in consideration of the payment of a total sum of four
thousand two hundred dollars ($4,200.00) by the County to Claimant and such other
consideration as provided for herein, the sufficiency of which Claimant acknowledges is fair,
reasonable and adequate, Claimant shall and does hereby agree to:
Fully and forever release and discharge the Board of County Commissioners of Grant
County and Grant County Superior Court Clerk, Kim Allen and the Grant County
Superior Court Clerk's Office, inclusive of their current and former employees, officials,
officers, insurers, and agents, in both their official and individual capacities, all of the
above together referred to herein as the "Released Parties," from any and all claims,
demands, liabilities, expenses, insurance provider subrogation, attorney fees, or property
of any kind whatsoever, known or unknown, which Claimant has or may have, or which
may hereafter accrue or become known, on account of, or which are attributable to,
Claimants claims.
2. The $4,200.00 settlement amount includes reimbursement for payments made
by Claimant to the Grant County Superior Court Clerk's Office between2010 and 2021.
3. It is understood and agreed by Claimant that the payment of the sum provided for
herein is being made to resolve disputed claims asserted by the Claimant against one or more of
the Released Parties and is intended to fully and finally settle all matters in dispute, or that could
be in dispute, between Claimant and the Released Parties arising from payments made by
Claimant to the Grant County Superior Court Clerk and that the payment does not constitute,
and is not to be construed as, an admission by the Released Parties or any wrongdoing, fault, or
liability concerning the payments made to the Grant County Superior Court Clerk's Office, and
that any claim of wrongdoing, faut, or liability is denied.
4. In furtherance of the intent and purpose of this Agreement, Claimant represents
and warrants as follows:
(a) He acknowledges that he may have sustained presently unknown and/or
uncontemplated loss, damage, expense, cost or injury resulting from the Incident.
(b) No promise or inducement has been made by the Released Parties to
secure the execution of this Agreement by Claimant, except those above-,
(c) Claimant has read and understands the entire Agreement and has had an
opportunity to obtain the assistance and advice of legal counsel of his own choosing, independent
of Stephen Kozer of and for Grant County Public Defense, with respect of this settlement and
release of his claims prior to signing this agreement.
(d) Claimant shall bear all of his own costs and expenses, including all
attorney fees, if any, incurred in the preparation, review, and approval of the Agreement and any
other documents necessary to resolve the Litigation.
5. All of the terms contained to the Agreement are contractual and not mere recital
and it shall be interpreted and enforced under the laws of the State of Washington. The venue for
any action commenced to interpret or enforce the terms of this Agreement shall be in the
Superior Court and for Grant County, Washington.
WHEREFORE the parties have agreed and placed their authorized signatures at the places
indicated below.
Grant County Claimant
Chair, Cin y 6arter
Board of County Commissioners,
Grant County, Washington
Date: Z I 11 Z,1Dz'�
Reviewed and approved:
Garth MMaio, Att. No. 11226
GrayetlCounty Prosecuting Attorney
PO x 37
35 C treet NW, Suite 104
Eph ata, WA 98823
71a
����! '�Varna ore
In and for his own behalf
Date: —711 1(c).
f /F
35 C Street NW, Suite 104
PO Box 37
Ephrata, WA 98823
(509) 754-6027
Director:
Staff Attorneys:
Brett Hill
Stephen Kozer
Susan 0,plebay
Investigator:
Da rod Bustainante
GRANT COUNTY'
U
1-j
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DEPARTMENT OF PUBLIC 1�EFENSE
35 C Street NW, Suite 104
PO Box 37
Ephrata, WA 98823
(509) 754-6027
Director:
Staff Attorneys:
Brett Hill
Stephen Kozer
Susan 0,plebay
Investigator:
Da rod Bustainante
Ellyn Berg
Tyson Lang
Brim Gpyinn
July 15, 2021
Mr. Garth Dano
Grant County Prosecutor
POB 37
Ephrata, Wash. 98823
Dated anis _'L 1.1 v" day of
Brett Bierley
Mark Arand
Dean Terri hon
Board of County Coni-rtiission&s
Q
rant unty,'�
'ashington
Co ..
Approve Disapp NIP
e Abstain
Dist# I Dist I Dist # I
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Dist #2Aid# 2 Dist -# 2
mist #
Dist #3 Dist # 3 Dist # 3
RE: Nt.v. Varnadore # 00-1-00050-5- Refund of Overpayment
Dear Mr. Dano,
Enclose please find the original Release Agreement and Complete Release of All Claims and W-
9 Tax Form . for Grant County's records .
I greatly appreciate you interceding between my self and the original deputy prosecutor assigned
to this case and resolving this short of formal civil legal proceedings .
I hope the Board of County Commissioners appreciate this also , and if need be I would without
reservation, express the same to them.
If Mr. Jerry Gingrich would kindly mark the check in the memo section "refund" that would
wrap up all of our concerns
Tb4'kV x7nvi
Encls — Release of Claims and W-9
CC: Client File
001. 1zS_'__S11b6q00
JUL 1 5, ZOZi
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