FULL AND FINAL RELEASE AND SETTLEMENT AGREEMENT

This Full and Final Release and Settlement Agreement (“Release”) is made this ___ day of
August, 2022, by Trevor Hughes (“Plaintiff”), Chief Paul Pazen, and the City and County of
Denver (collectively the “Denver Defendants”).

WHEREAS, Plaintiff and Denver Defendants are parties to a civil action captioned Trevor
Hughes v. the City and County of Denver, Colorado, Jefferson County Colorado, Golden
Colorado, Arvada Colorado, Chief of Police Paul Pazen and John Doe, filed in the U.S. District
Court for the District of Colorado, Case Number 1:21-cv-02238-REB-MEH (“Lawsuit”).

WHEREAS, Plaintiff and the Denver Defendants desire to settle all damage claims
asserted in the above-referenced Lawsuit, and to enter into various agreements related to said
Lawsuit, including the events giving rise thereto, in accordance with the provisions and upon the
terms and conditions hereafter set forth.

IN CONSIDERATION of payment of the sum of Three Hundred Fifty Thousand Dollars

and No Cents ($350,000.00), payable to Killmer, Lane & Newman LLP COLTAF Client Trust
Account, Plaintiff agrees as follows:

1. Plaintiff hereby releases, acquits, and forever discharges the Denver Defendants,
their successors, and assigns, and any and all other related persons and entities, both past and
present, including, but not limited to, the City & County of Denver’s departments, agencies,
divisions, principals, attorneys, agents, employees, employers, successors, servants, elected
officials, officers, and directors, of and from any and all liabilities, claims, demands, rights,
controversies, agreements, damages, actions, causes of actions, expenses, attorney fees, interest,
compensation, judgment, and any and all consequential and punitive damages, of whatsoever kind
and nature, either in law or in equity, which might exist with regard to all claims related to or
giving rise to the Lawsuit, including, but not limited to, Plaintiff’s encounter with the Denver
Police Department on May 31, 2020.

2. Plaintiff hereby acknowledges and understands that the settlement referenced

herein is conditioned upon approval of the Denver City Council. If the Denver City Council fails
to approve or fund the payment of monetary consideration set forth herein, this Release becomes
null and void. Plaintiff further understands and agrees that the terms of this Release shall be kept
confidential unless and until the Denver City Council approves the Release.

3. Plaintiff acknowledges and agrees that this Release, and the terms thereof, shall be
binding on Plaintiff’s agents, attorneys, servants, employers, employees, principals, heirs,
executors, administrators, insurers, successors, assigns, subrogees, and any and all other persons
or entities which have or may have any claim on his behalf or may be entitled to share in any
settlement thereof.

4. Plaintiff understands and agrees that the payment of the above-referenced sum is in
full settlement of and is a compromise of Plaintiff’s disputed claims against the Denver Defendants
and Denver employees; that payment made under this Release is not to be construed as an

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admission of liability on the part of Denver, Chief Pazen, or its employees and that any liability is
hereby expressly denied.

5. Plaintiff acknowledges that a portion of the consideration given for this Release is
being given for the full and final release of any and all unknown losses, claims, injuries, costs,
expenses, and damages with respect to the Lawsuit which may have occurred in the past and are
not yet known, or which may occur in the future and are not presently known. Plaintiff agrees to
voluntarily and knowingly assume the risk of any mistake of fact, either mutual or unilateral, with
respect to said losses, claims, injuries, costs, expenses, and damages, and shall not, under any
circumstances, seek to present further claims against Denver itself or on behalf of its agents,
attorneys, servants, employers, employees, heirs, executors, administrators, insurers, successors,
assigns, and subrogees.

6. Plaintiff represents that any and all subrogated interests or liens that are in any way
related to the above-referenced Lawsuit have been resolved or will be resolved upon receipt of
payment as set forth above. It is understood and agreed that this Release is intended to forever
discharge any and all subrogated interests or liens which are in any way related to the above-
referenced Lawsuit. Plaintiff agrees to defend, indemnify, and hold Denver and its employees
harmless from any and all claims, actions, and liability whatsoever, including any attorney fees or
costs incurred by Denver which might arise from any unpaid or unsatisfied subrogated interest or
lien which is in any way related to the above-referenced Lawsuit. Plaintiff further agrees that in
the event any other provision of this Release is deemed unenforceable and invalid for any reason,
it is Plaintiff’s express intent and understanding that this provision of the Release be viewed as a
separately bargained for and independent provision.

7. Plaintiff further covenants and agrees that he will not bring any action at law,
proceeding in equity, administrative proceeding or otherwise, nor prosecute or sue the Denver
Defendants or Denver employees by way of complaint, counterclaim, or by any other manner at
all, relating to the facts and claims which were or could have been asserted in the Lawsuit.

8. Plaintiff understands and agrees that this Release is further intended to and does
release, acquit, and forever discharge any and all claims for attorney fees or other litigation
expenses which might exist with regard to the Lawsuit as against Denver and its employees.

9. Plaintiff hereby assumes responsibility for any and all tax consequences associated
with the settlement referenced herein. Plaintiff and/or any designated payee agrees to complete all
necessary documents, including, but not limited to, a W-9 form dated in the year payment is to be
made to fully execute this Release.

10. Upon receipt of the settlement funds, the Plaintiff will file a notice of dismissal with
the federal court. Plaintiff agrees to include the term “each party agrees to pay their own costs and
attorney fees” within the Stipulated Motion to Dismiss.

11. It is further understood and agreed that no promise, inducement, or agreement not
herein expressed has been made to Plaintiff; that this Release contains the entire terms of the
agreement between the Plaintiff and the Denver Defendants; that the terms are contractual and not

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a mere recital; and that this Release shall be construed according to the laws of the State of
Colorado. Each Party, through counsel, participated in the preparation of this Release, and no rules
of construction or interpretation based upon which party drafted any portion of the Release shall
be applicable or invoked.

12. Every provision of this Release is intended to be severable, unless otherwise noted.
If any term or provision hereof is declared to be illegal or invalid, for any reason whatsoever by a
court of competent jurisdiction, such illegality or invalidity shall not affect the balance of the terms
and provisions hereof, which terms and provisions shall remain binding and enforceable.

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APPROVED AS TO FORM AND CONTENT:

____________________________________
Andy McNulty
Attorney for Plaintiff

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