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allegedly arising from the operation of the Ivy landfill in Albemarle County, a solid waste <br />• management facility currently owned and operated by the RSWA; <br />WHEREAS, the Booth Plaintiffs have settled their claims brought in this Action with the <br />Defendants under a separate settlement agreement approved by the Court and thus are not Parties <br />to this Agreement; <br />WHEREAS, the Webers and the Stranges have not settled their claims brought in this <br />Action with the Defendants and thus are not Parties to this Agreement; <br />WHEREAS, the Defendants have denied and continue to deny Plaintiffs' allegations and <br />claims for relief in the Action, including but not limited to the allegations and claims asserted by <br />the Webers and the Stranges, and Defendants have asserted certain defenses in the Action; <br />WHEREAS, the Parties believe it is in their mutual interest to reach an amicable <br />resolution and compromise with respect to the disputes framed in the Action, without any <br />• admission of liability; <br />WHEREAS, the Parties, without waiver of any position taken in or any defense asserted <br />in the Action, and without admission or adjudication of any issue of fact or law, agree that the <br />Action should be settled; and <br />WHEREAS, the Parties wish to avoid the expense and uncertainty associated with <br />continued litigation and to resolve conclusively all claims and disputes among them, without <br />admitting any liability. <br />NOW, THEREFORE, in consideration of the mutual promises and covenants contained <br />herein, and for good and valuable consideration, the receipt and sufficiency of which is hereby <br />acknowledged, the Parties agree as follows: <br />• <br />19 <br />