NORTON RELEASE FOR BOS SIGNATURE.PDF

MUTUAL RELEASE AND SETTLEMENT AGREEMENT

This Mutual Release and Settlement Agreement ("Agreement") is made and entered
into this day of September, 2021, by and between the "Parties" Lisa Norton and William
Bruce Norton, husband and wife (the “Nortons") on the one hand, and Maricopa County, former
Maricopa County Sheriff Joseph M. Arpaio in his capacity as sheriff and individually, Maricopa
County Sheriff Paul Penzone, in his capacity as sheriff, and Maricopa County Sheriff's Office
officers Joshua Henderson, Christopher Hechavarria, and Sean Locksa (collectively the "County"
or “County Defendants”).

RECITALS:

1. The Nortons served a Notice of Claim Pursuant to A.R.S. §12-821.01 dated
July 21, 2014 regarding claims for Wrongful Arrest of Mrs. Norton against the County Defendants.

2. The Nortons served a Notice of Claim Pursuant to A.R.S. §12-821.01 dated
July 21, 2014 regarding claims for Defamation of Mrs. Norton against the County Defendants.

3. On January 20, 2015 the Nortons filed their initial Complaint in United
States District Court for the District of Arizona in Case No. 2:15-cv-00087 against the County
Defendants.

4. On April 23, 2015 the Nortons filed their First Amended Complaint in
United States District Court for the District of Arizona in Case No. 2:15-cv-00087 against the
County Defendants.

5. On June 16, 2015 the Nortons filed their Second Amended Complaint in
United States District Court for the District of Arizona in Case No. 2:15-cv-00087 against the
County Defendants and on June 19, 2015 a Corrected Second Amended Complaint.

6. To avoid additional litigation and further expense, the Parties have mutually
agreed to compromise and settle forever any claims which they may have against each other arising
out of the facts set forth above by executing this Mutual Release and Settlement Agreement.

NOW, THEREFORE, in consideration of the Recitals and of the covenants and
conditions contained herein, and in exchange for good and valuable consideration, receipt of which
is hereby acknowledged:

1. The parties acknowledge and agree that the foregoing recitals are accurate
and incorporate such recitals as part of this Agreement as if fully set forth herein.

2. The County agrees to pay to the Nortons the sum of $400,000.00 to settle
all claims between the Nortons and the County Defendants that were, or could have been raised as

soon a result of the facts set forth in any of the Notices of Claims or Initial or Amended Complaints
listed in the Recitals above (the “Settlement Payment”). The Parties agree that the Settlement
Payment is made as compensation for the Norton’s personal injury tort claims.

3. The settlement check shall be made out to Gordon & Rees, LLP on behalf
of their clients Lisa and Bruce Norton and mailed to Leon Silver, Gordon Rees Scully Mansukhani,
Two North Central, Suite 2200, Phoenix, Arizona, 85004.

4. The Parties shall cause to be filed a Notice of Partial Settlement in Case No.
2:15-cv-00087 as soon as practical. Upon delivery of the Settlement Payment and a fully executed
copy of this Agreement, the Parties shall cause to be filed a Notice of Voluntary Partial Dismissal
with Prejudice of the Nortons’ claims in Case No. 2:15-cv-00087

5. Upon execution of this agreement, and payment as provided for in
paragraph 2 above, the Nortons do hereby, for themselves, and their respective legal predecessors
in interest, legal successors and assigns, release and absolutely forever discharge the County, and
all of the entities and employees named in the Complaints and their respective shareholders,
officers, directors, employees, agents, trustees, fiduciaries, beneficiaries, attorneys, legal
successors and assigns of and from any and all claims, demands, damages, debts, liabilities,
accounts, obligations, costs, expenses, liens, actions and causes of action of every kind and nature
whatsoever, whether now known or unknown, suspected or unsuspected which these parties now
have, own or hold, or any time heretofore have ever had owned or held or could, shall or may
hereafter have, own or hold against each other based upon or arising in any way out of the
transactions which have been described herein before, except that this Release shall in no way
impact the claims of any other plaintiffs in Case No. 2:15-cv-00087 against the County
Defendants.

6. The Parties agree that this matter is of a sensitive and personal nature and
therefore agree that, to the extent allowable under applicable law, they shall keep the terms of this
agreement confidential. The parties recognize that Maricopa County is a public entity and that
settlements with public entities are matters of public record and therefore accept the limitations
which that fact places on the defendants’ ability to maintain confidentiality.

7. The Parties expressly represent and warrant that they are authorized to
execute this Agreement. Further, the Parties expressly acknowledge that they have been
represented by their counsel in connection with the preparation of this Agreement. This
Agreement has been negotiated and drafted jointly by the Parties and their respective counsel, and
the terms, conditions and provisions of this Agreement shall be construed only according to their
fair import and shall not be construed for or against any Party hereto.

8. The Parties further represent and warrant that they have not assigned,
transferred or conveyed any of their respective rights, claims or causes of action relating to the
subject matter of this Agreement and expressly waive all rights they may have to do so.

9. This Agreement is executed as a compromise of disputed claims, liability
for which is expressly denied by the Parties. By this Agreement, the Parties do not admit any

wrongdoing or liability, nor do the Parties intend it to be construed as such.

10. The Parties hereto agree not to disparage or defame one another or any of
the Released Parties hereunder.

11. The Parties agree that each of them shall take such further action and
execute such further documents, if any, which may be necessary or appropriate to implement this
Agreement according to its terms.

12. This Agreement is made with reference to and under the terms of laws of
the State of Arizona which will be deemed to govern the validity and interpretation of this
Agreement and the rights and remedies of the parties hereunder. The Parties hereby agree that
they are subject to the Jurisdiction of the State and Federal Courts within the State of Arizona.
Any legal action instituted by the Parties arising out of this Agreement shall be subject to the
exclusive jurisdiction of the State or Federal Courts within the State of Arizona.

13. This Agreement constitutes the entire agreement between the parties and
supersedes all prior verbal or written agreements and understanding between the parties. No
agreement or promise is binding on any party except as set forth herein. Any modification or
waiver of any term of this Agreement, including a modification or waiver of these terms, must be
in writing and signed by both parties.

14. This Agreement shall be enforced as a whole and no portion of the Agreement
shall be severable. Time is of the essence of this Agreement. The parties agree to cooperate to
effectuate this Agreement.

15. All representations, warranties, indemnities, and covenants made by the
parties hereto in the Agreement shall survive the execution of the Agreement. The recitals
hereinbefore set forth shall be considered a part of this Agreement.

16. This Agreement shall be binding upon and inure to the benefit of the parties
hereto, their successors, and assigns.

17. This Agreement may be executed in any number of counterparts, each of
which, when executed, shall be an original and all of which together shall constitutes one and the
same Agreement.

IN WITNESS WHEREOF, the parties have executed this Mutual Release and
Settlement Agreement the day and year first above written.

IN WITNESS WHEREOF, the parbes have vxccutced this Mutual Release and

Settlement Agrectent the day and seat first ghove water,
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Lisa Naplon

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Milka Bruce Nortan

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MARICOPA COUNTY
BOARD OF SUPERVISORS

BY,

Charman. Board of Super inocs

Paty
ATTEST

Cleth af the Board

Date
Apmoved as to form

A. Arthur bascs. Sanders & Parks

Date

Lisa Norton

William Bruce Norton

Approved as to Form and Content:

Leon B. Silver, Gordon Rees Scully Mansukhani
Attorneys for Plaintiffs

MARICOPA COUNTY
BOARD OF SUPERVISORS

BY:

Chairman, Board of Supervisors

Date:

ATTEST:

Clerk of the Board

Date:

Approved as to form:

O Oth Erin /

J. Arthur Eaves, Sanders & Parks

Date: September 17, 2021