South Bend Common Council vs. South Bend City Administration in Superior Court - Filing on January 29, 2018
"C. The parties now desire that the Disputes which now exist, had
previously existed or may have existed between them regarding the Recordings
and/or alleged use of Recordings (which Disputes have been the subject of
respective lawsuits described above and are now cpllectively referred to as the
“Lawsuits”) be immediately settled and that the Parties be spared the trouble and
expense of further litigation.
(From Paragraph 1 on Page 2 of Settlement Agreement)
A. The City will pay to Tim Corbett, Steve Richmond, David Wells,
Brian Young and Sandy Young the total sum of $500,000.00 made
payable to each Plaintiff and Pfeifer, Morgan & Stesiak.
B. The Parties acknowledge that the Recordings and the tape cassettes
(the “Cassettes”) which contain portions of the Recordings and which
were made by Karen DePaepe and given to Darryl Boykins remain the
subject of a subpoena by the common Council of South Bend (the
“Subpoena”). The Plaintiffs will continue to pursue their declaratory
judgment action seeking to quash the Subpoena. The City will comply
with any ruling on the validity of the Subpoena. However, if the
Plaintiffs prevail, the city will deliver the Cassettes to legal counsel for
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Citizens attending community events to inform other Citizens.