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• above; and <br />C. The completion of the property conveyances described in ¶ C. 4, <br />d. The reimbursement of $10,000 in expenses to the Batton Plaintiffs <br />described in ¶ C.2 above. <br />E. Miscellaneous Requirements. <br />1. The Parties agree to issue a joint public statement upon entry of the Order <br />of the Court dismissing the Plaintiffs from this Action as settled pursuant to the terms of this <br />Agreement, which statement shall be substantially the same as the statement attached hereto as <br />Exhibit 5. <br />2. The Plaintiffs, to the extent that they have control over such matters, agree <br />to remove the Ivy Steering Committee website and any language or images from any personal <br />websites and billboards, from the public domain which deal with any of the matters raised in the <br />0 Action with respect to the Ivy landfill. <br />• <br />3. The Parties agree to jointly move the Court to incorporate the terms and <br />conditions of this Agreement into its Order dismissing this Action as settled pursuant to terms of <br />this Agreement, and retain jurisdiction over this matter for purposes of adjudicating any disputes <br />that may arise between the parties with respect to the terms of this Settlement Agreement and <br />Release. <br />RELEASE BY PLAINTIFFS <br />The Plaintiffs hereby release, remise, and forever discharge Defendants, jointly and <br />severally, from any and all claims, causes of action or liabilities of every kind and nature, known <br />or unknown, past, present and future, whether arising under statutory or common law that have <br />been raised or could have been raised in the Action; provided, however, that this release shall not <br />33 <br />