UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

DANIEL HANDELMAN, plaintiff

Civil Action No. 99CV74612DT

Honorable Arthur J. Tarnow

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STIPULATION FOR COMPROMISE SETTLEMENT

It is hereby stipulated by and between Daniel Handelman plaintiff, and the United States of

America, Defendant, by and through their respective attorneys as follows:

      1. The parties do hereby agree to settle and compromise the above-entitled action under the

terms and conditions set forth herein.

      2. The United States of America, defendant, agrees to pay to the plaintiff Daniel

Handelman and his attorneys, Kurt Berggren, Michael J. Steinberg and Nancy Chang, the

sum of Fifteen Thousand and No Hundredths dollars ($15,000.00), which sum shall be in full

settlement and satisfaction of any and all claims, demands, rights, and causes of action of

whatsoever kind and nature, arising from, and by reason of any and all known and unknown,

foreseen and

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resulting, and to result, from the seizure, detention and release of the property which is the

subject of this action, and any other subject matter that gave rise to the above-captioned lawsuit,

including any claims of wrongful death, for which plaintiff Daniel Handelman or his heirs,

executors, administrators, or assigns, and each of them, now have or may hereafter acquire

against the United States of America, its agents, servants, and employees.

      3. Plaintiff Daniel Handelman and his heirs, executors, administrators or assigns hereby

agree to accept the sum of Fifteen Thousand and No Hundredths dollars ($15,000.00), in full

settlement and satisfaction of any and all claims, demands, rights, and causes of action of

whatsoever kind and nature, arising from, and by reason of any and all known and unknown,

foreseen and unforeseen bodily and personal injuries, damage to property and the consequences

thereof which they may have or hereafter acquire against the United States of America, its agents,

servants, and employees on account of the seizure, detention and release of the property which is

the subject of this action, and any other subject matter that gave rise to the above-captioned lawsuit,

including any claims of wrongful death. Plaintiff Daniel Handelman and his heirs,

executors, administrators, or assigns further agree to reimburse, indemnify, and hold harmless the

United States of

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action, claims, liens, rights or subrogated or contribution interests incident to or resulting from

further litigation or the prosecution of claims by plaintiff Daniel Handelman or his heirs,

executors, administrators, or assigns against any third party or against the United States, including

wrongful death.

      4. This stipulation for compromise shall not constitute an admission of liability or fault on

the part of the United States, its agents, servants, or employees, and is entered into by both parties

for the purpose of compromising disputed claims and avoiding the expenses and risks of litigation.

      5. It is also agreed, by and among the parties, that the settlement amount of Fifteen

Thousand and No Hundredths dollars ($15,000.00) represents the entire amount of the

compromise settlement and that the respective parties will each bear their own costs, fees and

expenses and that any attorney fees owed by the plaintiff, or payable by the defendant pursuant to

the Equal Access to Justice Act or otherwise, will be paid out of the settlement amount and not in

addition thereto.

      6. Payment of the settlement amount will be made by check drawn on the Treasury of the

United States for Fifteen Thousand and No Hundredths dollars ($15,000.00) and made payable to

Daniel Handelman, and plaintiff's attorneys, Kurt Berggren, Michael J.

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address: 412 East Huron Street, Ann Arbor, Michigan 48104. Plaintiff's attorneys agree to

distribute the settlement and proceeds among the plaintiff.

      7. In consideration of the payment of Fifteen Thousand and No Hundredths dollars

($15,000.00) as set forth above, plaintiff Daniel Handelman agrees that he will cause his attorneys

to execute and file with the court such documents as shall be necessary to cause the above-styled

action to be dismissed with prejudice from the docket of the court.

Executed this 23rd day of May, 2000.

SAUL A. GREEN
United States Attorney

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Daniel Handelman

Carolyn Bell Harbin

Plaintiff

Attorneys for Defendant

United States of America

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Michael J. Steinberg
Attorney for Plaintiff

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Nancy Chang
Attorney for Plaintiff

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