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G. Pursuant to Federal Rule of Civil Procedure 23, the Court will determine <br /> whether this Agreement as a whole is fair and reasonable and whether to approve or reject <br /> the entire Agreement. <br /> H. On or before October 1, 2004, Plaintiffs' Counsel shall notify the County of the <br /> portion of the $1.8 million settlement amount that would be attributable to regular rate <br /> damages for police officers and firefighters hired after July 1, 2002. Upon confirmation by <br /> the County, these amounts shall be deducted from the First Payment referred to in <br /> Paragraph 5. <br /> 18. Each Plaintiff receiving money pursuant to this Agreement shall be solely responsible <br /> for the payment of any income or other taxes on the amounts paid to or on behalf of the Plaintiff. <br /> 19. It is expressly understood and agreed that this Agreement, and the consideration stated <br /> herein, represents a final and complete compromise of disputed claims. It if further understood and <br /> agreed that the County denies any and all liability and that this Settlement Agreement, is not an <br /> admission of liability, but an agreement to avoid future costly litigation. This Agreement contains <br /> the entire agreement between the parties. <br /> 20. Plaintiffs acknowledge that they have carefully read the foregoing provisions, know the <br /> contents thereof, and have had the opportunity to review this Agreement with their attorneys. <br /> Agreed this 18th day of September, 2004. <br /> COUNTY OF HAWAII: PLAIN F <br /> A . ~ ......7 T <br /> Lincoln S. TCCAshida Vladimir Deve sq. <br /> Corporation Counsel <br /> Katherine Garcon Attorney for Plaintiffs <br /> Deputy Corporation Counsel <br /> 7 <br /> <br /> " Ted H. S. Hong' <br /> Attorney at Law <br /> Attorneys for Defendant <br /> 5 <br /> <br />