SETTLEMENT AGREEMENT AND FULL AND FINAL RELEASE
This Settlement Agreement and Full and Final Release ("Agreement") is entered into byand between Plaintiffs, Maryland Manor Associates and Buckhead Investment Partners. Inc., andDefendant, City of Houston.
I. DEFINITIONS1. "Agreement"
means this Settlement Agreement and Full and Final Release.
"City" means the City of Houston, Texas, a Texas home rule municipality, and itsagents, assigns, successors, predecessors, or other persons acting or purporting toact for or on its
means all of the following:
All past, present, known, and unknown claims, demands, andcauses of action for all damages, attorneys' fees, injunctive
costs, expenses, losses, and remedies that arisedirectly or indirectly out of or in connection with the City'shandling of the Project prior to the Effective Date of thisAgreement.
Subsection (a), above, includes all such claims, demand, or causesof action for alleged violations of any state or federal civil rights(including 42 U.S.C. § 1983, substantive or procedural dueprocess, or equal protection), statutory vested rights, inversecondemnation, regulatory taking, trespass, unjust enrichment,injunctive
constructive trust and/orresulting trust;