HomeMy WebLinkAboutCRA-R-26-0046 Exhibit A - Signed Copy of Settlement Agreement and ReleaseDocusign Envelope ID: 3491 ABD9-082C-8DD2-81 EE-53B13E392CF7
SETTLEMENT AGREEMENT AND RELEASE
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This Settlement Agreement and Release ("Agreement") is agreed to by and between Southeast Overtown/Park West
Community Redevelopment Agency,a public agency and body corporate created pursuant to Section 163.356, Florida
Statutes. (hereinafter "Claimant"), Mia Creative Lab LIc (hereinafter "Jean Salazar"), and State National Insurance
Company, Inc., National Specialty Insurance Company, Next Claims Management, Inc., Next Insurance US Company,
and Next Insurance, Inc. (hereinafter "Next") (all jointly referred to herein as the "Parties.")
WHEREAS, Claimant has alleged that on or about 05/20/2026, property damage, at 1074 NW 3rd Ave, Miami, FL,
33136, that resulted due to Jean Salazar business activities (the "Incident").
WHEREAS, the Parties desire to resolve this dispute, and any claims or causes of action the parties may have arising
from the Incident, without the expense of litigation;
WHEREAS, the Parties desire to enter into this Agreement in full settlement and discharge of all claims and/or causes
of action held by Claimant against Jean Salazarand Next arising from or related to the Incident;
NOW, THEREFORE, in consideration of mutual promises and obligations set forth herein, the receipt and sufficiency
of which are conclusively acknowledged, the Parties agree as follows:
Next agrees to pay, on behalf of Jean Salazar, and Claimant agrees to accept, the total sum of $1,560.00 (the
"Settlement Amount") to be paid upon execution of this Agreement.
No Admission of Liability. Claimant expressly understands and agrees that the acceptance of the provisions in this
Agreement constitutes neither an admission, nor a concession of liability on the part of Jean Salazar who expressly
denies any liability whatsoever. It is agreed that it is the intent of the Agreement to avoid the costs and burden of
litigation.
Release. Except as otherwise provided in this Agreement, Claimant hereby releases and forever discharges Jean
Salazar and Next, and their agents, attorneys, representatives and employees, affiliates, predecessors, successors,
heirs, assigns, insurers and reinsurers from any and all manner of action or actions, causes of action, whether at law
or equity, suits, debts, liens, contracts, agreements, promises, liabilities, claims, demands, damages, losses, costs or
expenses of any nature whatsoever, fixed or contingent, arising or resulting from the Incident, which Claimant may
have against Jean Salazar or Next.
The Parties agree as a further consideration and inducement for this compromise and release of claims that the
releases contained in this Agreement shall apply to all unknown and unanticipated injuries and damages resulting
from the Incident, as well as those now disclosed.
Authority. Claimant warrants and represents that the person executing this Agreement on its behalf is authorized to
do so. Claimant acknowledges that it has not assigned, nor does any other person have any interest in, the claims,
issues, causes of action or other matters released and discharged by this Agreement.
Liens. Claimant warrants and represents that upon receipt of the Settlement Amount, Claimant will indemnify and
defend Jean Salazaror Next against any liens for services provided to Claimant arising from or related to the Incident.
Claimant will release and hold Defendant and its insurers free and harmless from any and all such liens.
Attorney's Fees. If any suit or action or other proceeding is commenced to enforce or interpret any of the terms or
provisions of this Agreement, each Party shall bear its own fees and expenses (including attorneys' fees) incurred in
connection with any such suit or action, or any resulting appeals.
Docusign Envelope ID: 3491 ABD9-082C-8DD2-81 EE-53B13E392CF7
Governing Law and Venue. This Release Agreement will be governed by and interpreted in accordance with the
laws of the State of Florida, without giving effect to the principles of conflicts of law of such state. The Parties hereby
agree that any action arising out of this Agreement will be brought solely in any state or federal court located in
Florida, Miami -Dade County. Both Parties hereby submit to the exclusive jurisdiction and venue of any such court.
THE PARTIES FURTHER AGREE, TO THE EXTENT PERMITTED BY APPLICABLE LAW, TO WAIVE ANY RIGHT
TO TRIAL BY JURY WITH RESPECT TO ANY CLAIM, COUNTERCLAIM OR ACTION ARISING FROM THE
TERMS OF THIS AGREEMENT.
Entirety of the Agreement. The Parties understand and acknowledge that this Agreement contains the entirety of
the Agreement between them and that there are no other oral or written, express or implied promises, agreements,
representations, or inducements not specified in this Agreement. The Parties agree that all of the terms in this
Agreement are contractual and not mere recitals. This Agreement supersedes any and all prior or contemporaneous
agreements or understandings between the parties.
IN WITNESS WHEREOF, the Claimant hereto has duly executed this Agreement on the date shown
below:
Signed by:
By: ,'iu t,S V, t/LGAt,t,1A.
Printea ivame B287D5438...
James D. McQueen
Dated:
August 3, 2026